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                                                                                           Department of the Treasury
                                                                                           Internal Revenue Service
Instructions for Form 8975 

and Schedule A (Form 8975)

(Rev. July 2019)
Country-by-Country Report

Section references are to the Internal Revenue Code unless       Additionally, the term “business entity” includes any entity 
otherwise noted.                                               with a single owner that may be disregarded as an entity 
                                                               separate from its owner under Regulations section 
Future Developments                                            301.7701-3, and any permanent establishment (described 
For the latest information about developments related to       below) that prepares financial statements separate from 
Form 8975, Schedule A (Form 8975), and their instructions,     those of its owner for financial or tax reporting, regulatory, or 
such as legislation enacted after they were published, go to   internal management control purposes.
IRS.gov/Form8975.                                                A decedent's estate or a bankruptcy estate described in 
                                                               section 1398 is not a business entity.
General Instructions                                           Constituent entity. With respect to a U.S. MNE group, a 
                                                               constituent entity is any separate business entity of such U.S. 
Purpose of Form                                                MNE group but does not include a foreign corporation or 
Certain United States persons that are the ultimate parent     foreign partnership for which information is not otherwise 
entity of a United States multinational enterprise (U.S. MNE)  required to be furnished under section 6038(a) (determined 
group with annual revenue for the preceding reporting period   without regard to Regulations sections 1.6038-2(j) and 
of $850 million or more are required to file Form 8975.        1.6038-3(c)) or any permanent establishment of such foreign 
                                                               corporation or foreign partnership.
Form 8975 and Schedules A (Form 8975) are used by 
filers described under Who Must File to annually report        Permanent establishment (PE).      The term “permanent 
certain information with respect to the filer’s U.S. MNE group establishment” includes:
on a country-by-country basis. The filer must list the U.S.    A branch or business establishment of a constituent entity 
MNE group’s constituent entities, indicating each entity’s tax in a tax jurisdiction that is treated as a permanent 
jurisdiction (if any), country of organization and main        establishment under an income tax convention to which that 
business activity, and provide financial and employee          tax jurisdiction is a party,
information for each tax jurisdiction in which the U.S. MNE    A branch or business establishment of a constituent entity 
does business. The financial information includes revenues,    that is liable to tax in the tax jurisdiction in which it is located 
profits, income taxes paid and accrued, stated capital,        pursuant to the domestic law of such tax jurisdiction, or
accumulated earnings, and tangible assets other than cash.     A branch or business establishment of a constituent entity 
                                                               that is treated in the same manner for tax purposes as an 
Form 8975 and its Schedules A (Form 8975) must be filed        entity separate from its owner by the owner's tax jurisdiction 
with the IRS with the income tax return of the ultimate parent of residence.
entity of a U.S. MNE group for the tax year in or within which 
the reporting period covered by the Form 8975 ends.            Reporting period. The reporting period covered by Form 
                                                               8975 and Schedules A (Form 8975) is generally the 
        Do not file Form 8975 and its Schedules A (Form        12-month period of your applicable financial statement that 
!       8975) separately from your income tax return.          ends with or within your tax year. If you do not prepare an 
CAUTION                                                        annual applicable financial statement, then the reporting 
                                                               period covered by Form 8975 and Schedules A (Form 8975) 
Definitions                                                    is generally the 12-month period that ends on the last day of 
For more information on the terms below, see Regulations       your tax year.
section 1.6038-4.                                              Tax jurisdiction. A tax jurisdiction is a country or a 
Applicable financial statement. An applicable financial        jurisdiction that is not a country but that has fiscal autonomy. 
statement is a certified audited financial statement that is   A U.S. territory or possession of the United States is 
accompanied by a report of an independent certified public     considered to have fiscal autonomy.
accountant or similarly qualified independent professional     Tax jurisdiction of residence. A business entity generally 
that is used for purposes of reporting to shareholders,        is considered a resident in a tax jurisdiction if, under the laws 
partners, or similar persons; for purposes of reporting to     of that tax jurisdiction, the business entity is liable to tax 
creditors in connection with securing or maintaining           therein based on place of management, place of 
financing; or for any other substantial non-tax purpose.       organization, or another similar basis. A business entity is not 
Business entity.  A business entity generally is any entity    considered a tax resident in a tax jurisdiction if the business 
recognized for federal tax purposes that is not properly       entity is liable to tax in such tax jurisdiction only by reason of 
classified as a trust under Regulations section 301.7701-4.    a tax imposed by reference to gross amounts of income 
However, any grantor trust within the meaning of section 671,  without any reduction for expenses, provided such tax 
all or a portion of which is owned by a person other than an   applies only with respect to income from sources in such tax 
individual, is considered a business entity.                   jurisdiction or capital situated therein.

Jul 01, 2019                                             Cat. No. 69160R



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  A corporation that is organized or managed in a tax                  traded on a public securities exchange in its tax jurisdiction of 
jurisdiction that does not impose an income tax on                     residence).
corporations will be treated as resident in that tax jurisdiction, 
unless such corporation is treated as resident in another tax          Who Must File
jurisdiction under the previously described rules.                     A U.S. person must file Form 8975 and Schedules A (Form 
  The tax jurisdiction of residence of a permanent                     8975) if it is the ultimate parent entity of a U.S. MNE group 
establishment is the jurisdiction in which the permanent               with revenues of $850 million or more in the immediately 
establishment is located.                                              preceding reporting period. A U.S. territory ultimate parent 
                                                                       entity may designate a U.S. business entity to file on its 
  A business entity that does not have a tax jurisdiction of 
                                                                       behalf.
residence is considered “stateless.”
Ultimate parent entity of a U.S. MNE group.  The ultimate              When making the determination of whether you are the 
parent entity of a U.S. MNE group is a U.S. business entity            ultimate parent entity of a U.S. MNE group, a business 
that:                                                                  entity’s tax jurisdiction of residence is the business entity’s 
Owns directly or indirectly a sufficient interest in one or          country of organization if the business entity does not 
more other business entities, at least one of which is                 otherwise have a tax jurisdiction of residence.
organized or tax resident in a tax jurisdiction other than the         Exceptions from filing. You are not required to file Form 
United States, such that the U.S. business entity is required          8975 if the annual revenue of your group for the immediately 
to consolidate the accounts of the other business entities             preceding reporting period was less than $850 million.
with its own accounts under U.S. GAAP (or that would be so 
required if publicly traded); and                                      When To File
Is not owned directly or indirectly by another business              Attach Form 8975 and Schedules A (Form 8975) to your 
entity that consolidates the accounts of such U.S. business            income tax return and file them with the IRS by the due date 
entity with its own accounts under GAAP in the other                   (including extensions) for that income tax return. The Form 
business entity's tax jurisdiction of residence (or that would         8975 and Schedules A (Form 8975) should be attached, if 
be so required if publicly traded in its tax jurisdiction of           applicable, to Forms 1120, 1065, 1065-B, 1120-S, 1120-L, 
residence).                                                            1120-PC, 1120-REIT, 990-T, and 1041.
U.S. business entity. A U.S. business entity is a business             Extension of time to file. To request an extension of time 
entity that is organized or has its tax jurisdiction of residence      to file Form 8975, you must follow the instructions for the 
in the United States. Foreign insurance companies that elect           income tax return to which Form 8975 and Schedules A 
to be treated as domestic corporations under section 953(d)            (Form 8975) will be attached.
are U.S. business entities that have their tax jurisdiction of 
residence in the United States. A business entity that is a            How To File
limited liability company that is organized in the United 
States, and is wholly owned (directly) by another business             Electronic Filing
entity that has its tax jurisdiction of residence and is               If you file your income tax return electronically, see the 
organized in the United States, will be considered a U.S.              instructions for the income tax return for general information 
business entity that has its tax jurisdiction of residence in the      about electronic filing.
United States.
                                                                       If you are filing Forms 1120, 1065, 1065-B, 1120-S, or 
U.S. MNE group. A U.S. MNE group comprises the ultimate                1041 electronically, you must attach Form 8975 and 
parent entity of a U.S. MNE group and all of the business              Schedules A (Form 8975) electronically in the correct format, 
entities required to consolidate their accounts with the               not as a binary attachment.
ultimate parent entity's accounts under U.S. GAAP (or that 
would be so required if publicly traded), regardless of                Note.  In order to ensure the timely automatic exchange of 
whether any such business entities could be excluded from              the information on Form 8975 and Schedules A (Form 8975), 
consolidation solely on size or materiality grounds.                   you are encouraged to file your return electronically.
  Business entities are not considered part of the U.S. MNE            Amended Form 8975.      If you file a Form 8975 and 
group if the income or assets of the business entities are             Schedules A (Form 8975) that you later determine should be 
included in the financial statements of the ultimate parent            amended, file an amended Form 8975 and all Schedules A 
entity based on the equity method or fair value accounting.            (Form 8975), including any that have not been amended, 
U.S. territory or possession of the United States.       The           with an amended tax return. Use the amended return 
term “U.S. territory or possession of the United States”               instructions for the return with which you originally filed Form 
means American Samoa, Guam, the Northern Mariana                       8975 and Schedules A (Form 8975) and check the amended 
Islands, Puerto Rico, and the U.S. Virgin Islands.                     report checkbox at the top of Form 8975.
U.S. territory ultimate parent entity. A U.S. territory                If the return and Form 8975 that you are amending were 
ultimate parent entity is a business entity organized in a U.S.        filed electronically with the IRS, then the amended return and 
territory or possession of the United States that controls (as         Form 8975 should be filed electronically with the IRS in order 
defined in section 6038(e)) a U.S. business entity and that is         to ensure timely automatic exchange of the information on 
not owned directly or indirectly by another business entity            Form 8975 and Schedules A (Form 8975).

that consolidates the accounts of the U.S. territory ultimate          Where To File
parent entity with its accounts under GAAP in the other 
business entity's tax jurisdiction of residence (or would be so        While most entities will be electronically filing their country-by 
required if equity interests in the other business entity were         country reports, some filers will not be able to file 
                                                                       electronically. This includes those filing Form 1120-REIT, 
                                                                       Form 990-T, filers of Form 1120-PC and 1120-L that are filing 

                                                                   -2-            Instructions for Form 8975 (Rev. July 2019)



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as parent entities, and filers of Form 1041 that choose not to 
                                                                   Part I—Identification of Filer
or are not required to file electronically. These filers should 
use the mailing addresses provided for the applicable              Use Part I to provide your identifying information.
income tax return. The Form 8975 and Schedules A (Form             Line 1a. Enter your complete legal name.
8975) must be attached to the applicable paper tax return.
                                                                   Line 1b. You are the reporting entity. Enter the code for your 
Paper-filed returns.   If filing on paper only, mail a copy of     reporting role. The reporting role indicates whether you are 
page 1 of your Form 8975 to the IRS. Mailing a copy of             filing as the ultimate parent entity of your group (enter code: 
page 1 of Form 8975 will notify the IRS that you have filed        ULT) or if you are filing because you were designated by a 
Form 8975 and Schedules A (Form 8975) with a paper return          U.S. territory ultimate parent entity to file on its behalf (enter 
and will assist the IRS in identifying paper returns that have     code: SUR).
Form 8975 and Schedules A (Form 8975) attached. Mail to 
the following address:                                             Line 1c. Enter your employer identification number (EIN).
                                                                   Lines 2 and 3a through 3c. Enter your legal address. 
Internal Revenue Service                                           Include the suite, room, or other unit number after the street 
Mailstop 4950                                                      address. If the post office does not deliver mail to the street 
1973 N. Rulon White Blvd.                                          address and you have a P.O. box, show the box number 
Ogden, UT 84201                                                    instead.
                                                                   Foreign address. Follow the country's practice for 
Record Maintenance                                                 entering the postal code, if any. Do not abbreviate the 
You are required to maintain records to support the                country name.

information provided on Form 8975 and Schedules A (Form            Part II—Additional Information
8975). However, you are not required to create and maintain 
records that reconcile the amounts provided on Form 8975           You can enter additional information related to your group, 
and Schedules A (Form 8975) with the income tax returns of         such as a narrative description of the overall business 
any tax jurisdiction or your applicable financial statements.      operations and structure of your group or an overall 
                                                                   assumption or convention that you used which might have an 
Penalties for Failure To File                                      effect on your report. Any financial amounts entered in Part II 
Penalties under section 6038(b) may apply for failure to           must be stated in U.S. dollars. You will have an opportunity to 
report the information required on this form.                      enter specific information regarding financial information and 
                                                                   constituent entities in each tax jurisdiction on the appropriate 
                                                                   Schedule A (Form 8975).
Specific Instructions for Form                                     If the additional information you choose to enter in Part II 
                                                                   will not fit in the allotted space, complete as many additional 
8975
                                                                   page 2, Part II, Additional Information sections as you need, 
There are two parts to Form 8975. You must complete the            and submit these additional page(s) with Form 8975.
information at the top of the form regarding reporting period 
and Part I. Completing Part II is optional.                        Specific Instructions for Schedule A 
At the top of Form 8975, enter the reporting period for which      (Form 8975)
you are filing.                                                    You must file a separate Schedule A (Form 8975) for each 
If filing an amended report (see Amended Form 8975,                tax jurisdiction in which your group has one or more 
earlier), check the amended report box.                            constituent entities resident. If you have any constituent 
                                                                   entities in your group that do not have a tax jurisdiction of 
Enter the number of Schedules A (Form 8975) attached to            residence (that is, the constituent entity is “stateless”), then 
Form 8975. You must attach at least one Schedule A (Form           you also must fill out a Schedule A (Form 8975) providing the 
8975) to your Form 8975 for each tax jurisdiction in which         information for each constituent entity that is stateless, 
your group operates, including the United States. Therefore,       reporting the financial and employee information in the 
you will file a separate Schedule A (Form 8975) for at least       aggregate with respect to those stateless constituent entities, 
two tax jurisdictions.                                             and indicating that there is no tax jurisdiction by providing the 
                                                                   appropriate “stateless” code. See Tax jurisdiction under Part 
Generally, at least one Schedule A (Form 8975) will be for         I—Tax Jurisdiction Information, later.
the United States. However, certain U.S. MNE groups may 
have only U.S.-organized constituent entities that are fiscally    The financial amounts furnished should be based on 
transparent. These fiscally transparent U.S. business entities     applicable financial statements, books and records 
do not have a tax jurisdiction of residence for purposes of        maintained with respect to the constituent entities, regulatory 
reporting information on Form 8975. Thus, these fiscally           financial statements, or records used for tax reporting or 
transparent U.S. business entities, along with all other           internal management control purposes for an annual period 
constituent entities of the U.S. MNE group that do not have a      of each constituent entity ending with or within the reporting 
tax jurisdiction of residence, should be reported on one           period.
Schedule A (Form 8975) that indicates the tax jurisdiction         At the top of each Schedule A (Form 8975), enter the 
“stateless.”                                                       reporting period, your name, and EIN. These should match 
If a filing does not have either a United States Schedule A        the information entered on Form 8975.
(Form 8975) or a “stateless” Schedule A (Form 8975) that           If a constituent entity in your group is the owner of another 
contains fiscally transparent U.S. business entities, then the     constituent entity in your group that is stateless, then the 
Form 8975 has not been completed properly.                         owner's share of such stateless entity's revenues and profits 

Instructions for Form 8975 (Rev. July 2019)                     -3-



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should be aggregated with the information for the owner's tax          Part I.  Enter the tax jurisdiction only. Do not complete lines 
jurisdiction of residence.                                             1 through 8 of Part I.
At each level, the owner entity includes its share of the              Part II. Complete Part II as needed to list all of the 
stateless entity’s revenue and profits in the owner’s tax              constituent entities resident in the tax jurisdiction.
jurisdiction of residence only if the owner has a tax 
jurisdiction of residence (that is, only if the owner is not           Part III. Enter a statement that indicates this is a 
stateless), and the amount of revenue of the top-tier stateless        continuation sheet, the tax jurisdiction to which the 
entity from which the owner entity calculates its share should         continuation sheet applies, and the page number of the 
include any allocations from stateless entities owned, directly        continuation sheets (for example, “Page 3 of 9”). Complete 
or indirectly, by the top-tier stateless entity, even if such          the rest of Part III as necessary.
allocations are excluded from the intermediate stateless 
                                                                       Part I—Tax Jurisdiction Information
entity’s revenue and profit.
                                                                       For each tax jurisdiction in which one or more constituent 
Example.    Assume US Corp is the ultimate parent entity               entities of your group is tax resident, you must provide 
of a U.S. MNE group. US Corp owns 90% of partnership P1                financial amounts and number of employees as an aggregate 
which in turn owns 80% of partnership P2. Both P1 and P2               of the information for the constituent entities resident in that 
do not have a tax jurisdiction of residence (that is, they are         tax jurisdiction.
stateless), each earns $100 of revenue and has no expenses 
(P1’s $100 of revenue does not include its allocable share of          Tax jurisdiction. This field is mandatory. Enter the 
P2’s revenue), and neither creates a permanent                         two-letter code for the tax jurisdiction to which the 
establishment (that is, taxable presence) in any tax                   Schedule A (Form 8975) pertains. The country code for the 
jurisdiction. Assume US Corp earns $100 of revenue, not                United States is “US” and the country code for “stateless” is 
including its share of P1’s revenue, and has no expenses.              “X5.” All other country codes can be found at IRS.gov/
                                                                       CountryCodes.
P2 has $100 of revenue and profit that is reflected on the 
stateless Schedule A revenue and profit lines. P1 has $100             Form 8975 and Schedule A (Form 8975) information is 
of revenue and profit that is reflected on the stateless               exchanged using the OECD Country Code List that is based 
Schedule A revenue and profit lines. Since P1 is stateless, it         on the ISO 3166-1 Standard. Although the country codes 
does not include its share of P2’s revenue and profit again on         found in the IRS link above contain the jurisdictions listed in 
the stateless Schedule A revenue or profit lines. The total            the table below, those jurisdictions do not correspond to a 
revenue and profit on the stateless Schedule A is $200.                valid OECD country code for purposes of exchanging the 
                                                                       information. Therefore, do not enter any of these country 
US Corp has $100 of revenue and profit, not including any 
                                                                       codes on the tax jurisdiction line of Part I of Schedule A 
allocations from other constituent entities. Since US Corp 
                                                                       (Form 8975).
has a tax jurisdiction of residence, it includes its share of P1’s 
revenue and profit on the Schedule A for the United States.                      Tax Jurisdiction                 Country Code
P1’s revenue and profit, of which US Corp is allocated 90%, 
includes any allocations from stateless entities that P1 owns,         Akrotiri                                   AX
even if such allocations were not included on the stateless            Ashmore and Cartier Islands                AT
Schedule A revenue or profit lines. P1’s revenue and profit            Clipperton Island                          IP
when determining US Corp’s allocable share is $180 (P1’s 
own $100 of revenue and profit plus 80% of P2’s revenue                Coral Sea Islands                          CR
and profit, or $80). US Corp is allocated 90% of $180, or              Dhekelia                                   DX
$162, of revenue and profit due to its ownership of P1. The 
                                                                       Paracel Islands                            PF
total revenue and profit on the United States Schedule A 
revenue and profit lines is US Corp’s own revenue and profit           Spratly Islands                            PG
of $100 plus its allocation of $162 of revenue and profit from 
P1, or $262.
                                                                       If the tax jurisdiction specified in the above list is 
Currency Translation                                                   associated with a larger sovereignty, use the country code for 
All currency amounts furnished must be in U.S. dollars. If an          the larger sovereignty with which the tax jurisdiction is 
exchange rate is used other than in accordance with U.S.               associated (e.g., Akrotiri and Dhekelia are considered a 
GAAP for translation to U.S. dollars, the exchange rate must           British Overseas Territory so the country code for the United 
be indicated in Part III, Additional Information, on the               Kingdom would be used (“UK”)). Otherwise, use a separate 
Schedule A (Form 8975) relating to the amounts that are not            Schedule A for “other country” using the tax jurisdiction code 
translated in accordance with U.S. GAAP.                               “OC.” In either case, you should include in Part III of 
                                                                       Schedule A (Form 8975) the name of the specific constituent 
Multiple Schedules A (Form 8975) for a Single                          entity and the jurisdiction where the constituent entity is 
Tax Jurisdiction                                                       located.
If you are filing on paper and the information you want to                      When you enter a country code in Schedule A (Form 
enter for a single tax jurisdiction does not fit on a single           !        8975), Part I, the financial and employee information 
Schedule A (Form 8975), you can attach additional                      CAUTION  in Part I, the constituent entity information in Part II, 
Schedules A (Form 8975). Complete the additional                       and the additional information in Part III must pertain to the 
Schedules A (Form 8975) as follows.                                    constituent entities that are tax resident in that jurisdiction.
Above Part I. Enter the reporting period beginning and                 In Part I, you will provide the aggregate amounts for all of 
ending dates, the name of the reporting entity, and the EIN.           the constituent entities listed in Part II.

                                                                   -4-                   Instructions for Form 8975 (Rev. July 2019)



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Lines 1a through 1c. In line 1a, enter the aggregate                   income earned by PE Y, then that income tax paid should be 
revenues of the constituent entities listed in Part II that are        reflected on the Schedule A for tax jurisdiction X. However, 
generated from transactions with those that are not                    income tax paid to tax jurisdiction Y on income earned by PE 
constituent entities in your group. In line 1b, enter the              Y is not included on the Schedule A for tax jurisdiction X, but 
aggregate revenues of the constituent entities listed in Part II       rather on the Schedule A for tax jurisdiction Y.
that are generated from transactions with other constituent            Line 5. Enter the aggregate amount of the stated capital of 
entities in your group. In line 1c, enter the total aggregate          the constituent entities listed in Part II.
revenues of the constituent entities listed in Part II.
                                                                       The stated capital of a permanent establishment must be 
The term “revenue” includes all amounts of revenue,                    reported in the tax jurisdiction of residence of the legal entity 
including revenue from sales of inventory and property,                of which it is a permanent establishment unless there is a 
services, royalties, interest, and premiums.                           defined capital requirement in the permanent establishment 
Revenue does not include payments received from other                  tax jurisdiction for regulatory purposes.
constituent entities in your group that are treated as                 Line 6. Enter the aggregate of total accumulated earnings of 
dividends in the payor's tax jurisdiction of residence.                the constituent entities listed in Part II. However, the 
Distributions and remittances from your constituent entities           accumulated earnings of a permanent establishment are 
that are partnerships, other fiscally transparent entities, or         considered those of the legal entity of which it is a permanent 
permanent establishments are not considered revenue of the             establishment and should be reported on the Schedule A 
recipient-owner.                                                       (Form 8975) for the tax jurisdiction of the legal entity owner.
Revenue also does not include imputed earnings or 
deemed dividends from other constituent entities in your               Line 7. Enter the aggregate number of employees on a 
group that are taken into account solely for tax purposes and          full-time equivalent basis of the constituent entities listed in 
that otherwise would be included as revenue by a constituent           Part II. The number of employees may be reported as of the 
entity.                                                                year-end, on the basis of average employment levels for the 
                                                                       year, or on any other basis consistently applied across tax 
For a constituent entity that is an exempt organization,               jurisdictions of your group and from year to year.
revenue means only revenue that is reflected in unrelated 
business taxable income. See Regulations section                       Reasonable rounding or approximation of the number of 
1.6038-4(d)(3)(ii).                                                    employees is permissible, provided that such rounding or 
                                                                       approximation does not materially distort the relative 
Line 2. Enter the aggregate profit or loss before income tax           distribution of employees across the various tax jurisdictions 
of the constituent entities listed in Part II.                         of your group. Consistent approaches should be applied from 
Line 3. Enter the aggregate amount of income tax paid on a             year to year and across entities.
cash basis to all tax jurisdictions by the constituent entities        Line 8. Enter the aggregate of the net book value of tangible 
listed in Part II and any taxes withheld on payments received          assets of all the constituent entities listed in Part II. For 
by the constituent entities listed in Part II.                         purposes of this schedule, tangible assets do not include 
Taxes paid should include taxes paid in cash by a                      cash or cash equivalents, intangibles, or financial assets.
constituent entity listed in Part II to its tax jurisdiction and to    For permanent establishments, assets should be reported 
all other tax jurisdictions. Taxes paid should include                 on the Schedule A (Form 8975) for the tax jurisdiction in 
withholding taxes paid by other entities (whether related or           which the permanent establishment is located.
unrelated) with respect to payments to the constituent 
entities in Part II.                                                   Part II—Constituent Entity 
Example. If, during a reporting period, Company X                      Information
(resident in tax jurisdiction X) generates operating income in         In this section, you will provide constituent entity information 
tax jurisdiction X that is subject to corporate income tax in tax      for your group regarding the constituent entities that have the 
jurisdiction X and earns interest income from a company in             tax jurisdiction indicated in Part I. You should complete a row 
tax jurisdiction Y subject to withholding tax in tax jurisdiction      for each constituent entity providing the information indicated 
Y, the taxes paid to tax jurisdiction X on the operating income        below.
and the tax withheld on the interest and paid to tax 
jurisdiction Y should be reported as part of the income taxes          Line 1. Enter the full legal name of the constituent entity, 
paid by Company X on the Schedule A for tax jurisdiction X.            including the domestic designation for the legal form, as 
                                                                       indicated in its articles of incorporation or any similar 
Line 4. Enter the aggregate of the total accrued current               document. If the constituent entity is a permanent 
income tax expense recorded on taxable profits or losses,              establishment, the naming convention to use is the name of 
reflecting only operations in the relevant annual period and           the constituent entity of which the permanent establishment 
excluding deferred taxes or provisions for uncertain tax               would be a part (if it were not its own constituent entity), 
liabilities, for the constituent entities listed in Part II.           followed by “- (PE).” For instance, if XYZ Corp has a 
When a constituent entity listed in Part II is a permanent             permanent establishment, that permanent establishment’s 
establishment, the amounts on line 3 and line 4 should not             name would be “XYZ Corp - (PE).”
include the income tax paid or current income tax expense              If filing electronically, the address of the constituent entity 
accrued by the business entity of which the permanent                  also may be provided.
establishment would otherwise be a part in that business 
entity’s tax jurisdiction of residence on the income derived by        Line 2. Enter the tax identification number (TIN), if any, used 
the permanent establishment. For example, if Company X                 for the constituent entity by the tax administration in the tax 
(resident in tax jurisdiction X) has a permanent establishment         jurisdiction of residence. The TIN is a mandatory field and 
“PE Y” in tax jurisdiction Y that is considered a constituent          must be entered for each constituent entity. If the constituent 
entity, and Company X pays tax jurisdiction X income tax on            entity does not have a TIN, then enter “NOTIN.”

Instructions for Form 8975 (Rev. July 2019)                         -5-



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  If filing electronically, one or more entity identification         feel this does not properly reflect the main businesses of a 
numbers (IN), such as a company registration number, can              constituent entity, you may use Part III, Additional 
be provided, along with the IN’s issuer country and type.             Information, on the appropriate Schedule A (Form 8975) to 
                                                                      enter additional codes and explain.
Line 3. Using the two-letter code from the list at IRS.gov/
CountryCodes, enter the tax jurisdiction in which the                 Line 4b.  If you entered the code for “Other” in line 4a, 
constituent entity is organized or incorporated if different from     describe the “Other” business activity.
the tax jurisdiction of residence. However, see Tax 
jurisdiction under Part I—Tax Jurisdiction Information, earlier,      Part III—Additional Information
for codes that are not allowed.                                       You can enter any relevant information or explanation that 
Line 4a. Identify the nature of the main business activity of         you deem necessary or that would facilitate the 
the constituent entity in the relevant tax jurisdiction by            understanding of the information provided in Parts I and II. 
selecting at least one of the following codes or categories.          The information may or may not relate to a specific 
CBC501 Research and development                                     constituent entity. The information may be used to explain 
CBC502 Holding or managing intellectual property                    the tax jurisdiction financial and employee information in Part 
CBC503 Purchasing or procurement                                    I, and you can use the item reference codes listed next to 
CBC504 Manufacturing or production                                  indicate if the additional information relates to a specific item 
CBC505 Sales, marketing, or distribution                            in Part I.
CBC506 Administrative, management, or support services              CBC601 Revenues—unrelated party
CBC507 Provision of services to unrelated parties                   CBC602 Revenues—related party
CBC508 Internal group finance                                       CBC603 Revenues—total
CBC509 Regulated financial services                                 CBC604 Profit or loss
CBC510 Insurance                                                    CBC605 Income tax paid
CBC511 Holding shares or other equity instruments                   CBC606 Income tax accrued
CBC512 Dormant                                                      CBC607 Stated capital
CBC513 Other                                                        CBC608 Accumulated earnings
                                                                      CBC609 Number of employees
  Those that do not file electronically are limited to indicating     CBC610 Tangible assets
a maximum of three main business activities. However, if you 

Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the 
United States. You are required to give us the information. We need it to ensure that you are complying with these laws and to 
allow us to figure and collect the right amount of tax.
  You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless 
the form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long 
as their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return 
information are confidential, as required by section 6103.
  The time needed to complete and file this form and related schedules will vary depending on individual circumstances. The 
estimated burden for taxpayers filing this form is approved under OMB control number 1545-2272. The estimated burden for all 
other taxpayers who file this form is shown below.

Form 8975 and Schedule A                                                                                              1hr., 30 min.

  If you have comments concerning the accuracy of these time estimates or suggestions for making this form and related 
schedule simpler, we would be happy to hear from you. See the instructions for the tax return with which this form is filed.

                                                                  -6-           Instructions for Form 8975 (Rev. July 2019)






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