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Department of the Treasury
Internal Revenue Service
Instructions for Form 8975

and Schedule A (Form 8975)

(Rev. December 2020)
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 U.S. persons that are the ultimate parent entity of a foreign partnership for which information is not otherwise
U.S. multinational enterprise (U.S. MNE) group with annual required to be furnished under section 6038(a) (determined
revenue for the preceding reporting period of $850 million or without regard to Regulations sections 1.6038-2(j) and
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 is
that is used for purposes of reporting to shareholders, generally considered a resident in a tax jurisdiction if, under
partners, or similar persons; for purposes of reporting to the laws of that tax jurisdiction, the business entity is liable for
creditors in connection with securing or maintaining tax therein based on place of management, place of
financing; or for any other substantial nontax purpose. organization, or another similar basis. A business entity is not
Business entity. A business entity is generally 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 for 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.

Sep 10, 2020 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, as 
be so required if publicly traded in its tax jurisdiction of           applicable, to Forms 1120, 1120-C, 1120-RIC, 1065, 1120-S, 
residence).                                                            1120-L, 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.
U.S. MNE group. A U.S. MNE group comprises the ultimate                If you are filing Forms 1120, 1065, 1120-S, 990-T, or 1041 
parent entity of a U.S. MNE group and all of the business              electronically, you must attach Form 8975 and Schedules A 
entities required to consolidate their accounts with the               (Form 8975) electronically in the correct format, not as a 
ultimate parent entity's accounts under U.S. GAAP (or that             binary attachment.
would be so required if publicly traded), regardless of 
whether any such business entities could be excluded from              Note.  Beginning January 2021, Form 990-T can be filed 
consolidation solely on size or materiality grounds.                   electronically.
  Business entities are not considered part of the U.S. MNE            Note.  In order to ensure the timely automatic exchange of 
group if the income or assets of the business entities are             the information on Form 8975 and Schedules A (Form 8975), 
included in the financial statements of the ultimate parent            you are encouraged to file your return electronically. In 
entity based on the equity method or fair value accounting.            certain cases, you are required to file your return 
U.S. territory or possession of the United States.       The           electronically.
term “U.S. territory or possession of the United States”               Amended Form 8975.      If you file a Form 8975 and 
means American Samoa, Guam, the Northern Mariana                       Schedules A (Form 8975) that you later determine should be 
Islands, Puerto Rico, and the U.S. Virgin Islands.                     amended, file an amended Form 8975 and all Schedules A 
U.S. territory ultimate parent entity. A U.S. territory                (Form 8975), including any that have not been amended, 
ultimate parent entity is a business entity organized in a U.S.        with an amended tax return. Use the amended return 
territory or possession of the United States that controls (as         instructions for the return with which you originally filed Form 
defined in section 6038(e)) a U.S. business entity and that is         8975 and Schedules A (Form 8975) and check the amended 
not owned directly or indirectly by another business entity            report checkbox at the top of Form 8975.
that consolidates the accounts of the U.S. territory ultimate          If the return and Form 8975 that you are amending were 
parent entity with its accounts under GAAP in the other                filed electronically with the IRS, then the amended return and 
business entity's tax jurisdiction of residence (or would be so        Form 8975 should be filed electronically with the IRS in order 
required if equity interests in the other business entity were         to ensure timely automatic exchange of the information on 
                                                                       Form 8975 and Schedules A (Form 8975).

                                                                   -2-                   Instructions for Form 8975 (Rev.12-2020)

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Schedule A (Form 8975) that indicates the tax jurisdiction
Where To File
“stateless.”
While most entities will be electronically filing their country-by
country reports, some filers will not be able to file If a filer does not have either a U.S. Schedule A (Form 8975)
electronically. This includes those filing Form 1120-REIT, or a “stateless” Schedule A (Form 8975) that contains fiscally
filers of Forms 1120-C, 1120-L, 1120-PC, and 1120-RIC that transparent U.S. business entities, then the Form 8975 has
are filing as parent entities, and filers of Form 1041 that not been completed properly.
choose not to or are not required to file electronically. These
filers should use the mailing addresses provided for the Part I—Identification of Filer
applicable income tax return. The Form 8975 and Schedules Use Part I to provide your identifying information.
A (Form 8975) must be attached to the applicable paper tax Line 1a. Enter your complete legal name.
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 Line 4. Enter the common name of the U.S. MNE group if it
8975). However, you are not required to create and maintain is significantly different from the reporting entity's name on
records that reconcile the amounts provided on Form 8975 line 1a.
and Schedules A (Form 8975) with the income tax returns of
any tax jurisdiction or your applicable financial statements. Part II—Additional Information
You can enter additional information related to your group,
Penalties for Failure To File such as a narrative description of the overall business
Penalties under section 6038(b) may apply for failure to operations and structure of your group or an overall
report the information required on this form. assumption or convention that you used which might have an
effect on your report. Any financial amounts entered in Part II
must be stated in U.S. dollars. You will have an opportunity to
Specific Instructions for Form enter specific information regarding financial information and
8975 constituent entities in each tax jurisdiction on the appropriate
Schedule A (Form 8975).
There are two parts to Form 8975. You must complete the
information at the top of the form regarding reporting period If the additional information you choose to enter in Part II
and Part I. Completing Part II is optional. will not fit in the allotted space, complete as many additional
page 2, Part II, Additional Information sections as you need,
At the top of Form 8975, enter the reporting period for which and submit these additional page(s) with Form 8975.
you are filing.
Note. If the common name of the U.S. MNE group is
If filing an amended report (see Amended Form 8975, significantly different from the reporting entity’s name, explain
earlier), check the amended report box. in the Additional Information section.
Enter the number of Schedules A (Form 8975) attached to
Form 8975. You must attach at least one Schedule A (Form Specific Instructions for Schedule A
8975) to your Form 8975 for each tax jurisdiction in which
(Form 8975)
your group operates, including the United States. Therefore,
you will file a separate Schedule A (Form 8975) for at least You must file a separate Schedule A (Form 8975) for each
two tax jurisdictions. tax jurisdiction in which your group has one or more
constituent entities resident. If you have any constituent
Generally, at least one Schedule A (Form 8975) will be for entities in your group that do not have a tax jurisdiction of
the United States. However, certain U.S. MNE groups may residence (that is, the constituent entity is “stateless”), then
have only U.S.-organized constituent entities that are fiscally you must also fill out a Schedule A (Form 8975) providing the
transparent. These fiscally transparent U.S. business entities information for each constituent entity that is stateless,
do not have a tax jurisdiction of residence for purposes of reporting the financial and employee information in the
reporting information on Form 8975. Thus, these fiscally aggregate with respect to those stateless constituent entities,
transparent U.S. business entities, along with all other and indicating that there is no tax jurisdiction by providing the
constituent entities of the U.S. MNE group that do not have a appropriate “stateless” code. See Tax jurisdiction under Part
tax jurisdiction of residence, should be reported on one I—Tax Jurisdiction Information, later.

Instructions for Form 8975 (Rev.12-2020) -3-

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The financial amounts furnished should be based on be indicated in Part III, Additional Information, on the
applicable financial statements, books and records Schedule A (Form 8975) relating to the amounts that are not
maintained with respect to the constituent entities, regulatory translated in accordance with U.S. GAAP.
financial statements, or records used for tax reporting or
internal management control purposes for an annual period Multiple Schedules A (Form 8975) for a Single
of each constituent entity ending with or within the reporting Tax Jurisdiction
period. If you are filing on paper and the information you want to
At the top of each Schedule A (Form 8975), enter the enter for a single tax jurisdiction does not fit on a single
reporting period, your name, and EIN. These should match Schedule A (Form 8975), you can attach additional
the information entered on Form 8975. Schedules A (Form 8975). Complete the additional
Schedules A (Form 8975) as follows.
If a constituent entity in your group is the owner of another
constituent entity in your group that is stateless, then the Above Part I. Enter the reporting period beginning and
owner's share of such stateless entity's revenues and profits ending dates, the name of the reporting entity, and the EIN.
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
Part III. Enter a statement that indicates this is a
jurisdiction of residence (that is, only if the owner is not
continuation sheet, the tax jurisdiction to which the
stateless), and the amount of revenue of the top-tier stateless
continuation sheet applies, and the page number of the
entity from which the owner entity calculates its share should
continuation sheets (for example, “Page 3 of 9”). Complete
include any allocations from stateless entities owned, directly
the rest of Part III as necessary.
or indirectly, by the top-tier stateless entity, even if such
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 (Form 8975) revenue and profit lines. Form 8975 and Schedule A (Form 8975) information is
P1 has $100 of revenue and profit that is reflected on the exchanged using the OECD Country Code List that is based
stateless Schedule A (Form 8975) revenue and profit lines. on the ISO 3166-1 Standard. Although the country codes
Since P1 is stateless, it does not include its share of P2’s found in the IRS link above contain the jurisdictions listed in
revenue and profit again on the stateless Schedule A (Form the table below, those jurisdictions do not correspond to a
8975) revenue or profit lines. The total revenue and profit on valid OECD country code for purposes of exchanging the
the stateless Schedule A (Form 8975) is $200. information. Therefore, do not enter any of these country
codes on the tax jurisdiction line of Part I of Schedule A
US Corp has $100 of revenue and profit, not including any (Form 8975).
allocations from other constituent entities. Since US Corp
has a tax jurisdiction of residence, it includes its share of P1’s Tax Jurisdiction Country Code
revenue and profit on the Schedule A (Form 8975) for the
United States. P1’s revenue and profit, of which US Corp is Akrotiri AX
allocated 90%, includes any allocations from stateless Ashmore and Cartier Islands AT
entities that P1 owns, even if such allocations were not Clipperton Island IP
included on the stateless Schedule A (Form 8975) revenue
or profit lines. P1’s revenue and profit when determining US Coral Sea Islands CR
Corp’s allocable share is $180 (P1’s own $100 of revenue Dhekelia DX
and profit plus 80% of P2’s revenue and profit, or $80). US Paracel Islands PF
Corp is allocated 90% of $180, or $162, of revenue and profit
due to its ownership of P1. The total revenue and profit on Spratly Islands PG
the United States Schedule A (Form 8975) revenue and profit
lines is US Corp’s own revenue and profit 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
associated with a larger sovereignty, use the country code for
Currency Translation the larger sovereignty with which the tax jurisdiction is
All currency amounts furnished must be in U.S. dollars. If an associated (for example, Akrotiri and Dhekelia are
exchange rate is used other than in accordance with U.S. considered a British Overseas Territory so the country code
GAAP for translation to U.S. dollars, the exchange rate must for the United Kingdom would be used (“UK”)). Otherwise,

-4- Instructions for Form 8975 (Rev.12-2020)

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use a separate Schedule A (Form 8975) for “other country” all other tax jurisdictions. Taxes paid should include
using the tax jurisdiction code “OC.” In either case, you withholding taxes paid by other entities (whether related or
should include in Part III of Schedule A (Form 8975) the unrelated) with respect to payments to the constituent
name of the specific constituent entity and the jurisdiction entities in Part II.
where the constituent entity is located. Example. If, during a reporting period, Company X
When you enter a country code in Schedule A (Form (resident in tax jurisdiction X) generates operating income in
tax jurisdiction X that is subject to corporate income tax in tax
! 8975), Part I, the financial and employee information
CAUTION in Part I, the constituent entity information in Part II, jurisdiction X and earns interest income from a company in
and the additional information in Part III, must pertain to the tax jurisdiction Y subject to withholding tax in tax jurisdiction
constituent entities that are tax resident in that jurisdiction. Y, the taxes paid to tax jurisdiction X on the operating income
and the tax withheld on the interest and paid to tax
In Part I, you will provide the aggregate amounts for all of jurisdiction Y should be reported as part of the income taxes
the constituent entities listed in Part II. paid by Company X on the Schedule A (Form 8975) for tax
Lines 1a through 1c. On line 1a, enter the aggregate jurisdiction X.
revenues of the constituent entities listed in Part II that are Line 4. Enter the aggregate of the total accrued current
generated from transactions with those that are not income tax expense recorded on taxable profits or losses,
constituent entities in your group. On line 1b, enter the reflecting only operations in the relevant annual period and
aggregate revenues of the constituent entities listed in Part II excluding deferred taxes or provisions for uncertain tax
that are generated from transactions with other constituent liabilities, for the constituent entities listed in Part II.
entities in your group. On line 1c, enter the total aggregate When a constituent entity listed in Part II is a permanent
revenues of the constituent entities listed in Part II. establishment, the amounts on line 3 and line 4 should not
The term “revenue” includes all amounts of revenue, include the income tax paid or current income tax expense
including revenue from sales of inventory and property, accrued by the business entity of which the permanent
services, royalties, interest, and premiums. establishment would otherwise be a part in that business
Revenue does not include payments received from other entity’s tax jurisdiction of residence on the income derived by
constituent entities in your group that are treated as the permanent establishment. For example, if Company X
dividends in the payor's tax jurisdiction of residence. (resident in tax jurisdiction X) has a permanent establishment
Distributions and remittances from your constituent entities “PE Y” in tax jurisdiction Y that is considered a constituent
that are partnerships, other fiscally transparent entities, or entity, and Company X pays tax jurisdiction X income tax on
permanent establishments are not considered revenue of the income earned by PE Y, then that income tax paid should be
recipient-owner. reflected on the Schedule A (Form 8975) for tax jurisdiction
Revenue also does not include imputed earnings or X. However, income tax paid to tax jurisdiction Y on income
deemed dividends from other constituent entities in your earned by PE Y is not included on the Schedule A (Form
group that are taken into account solely for tax purposes and 8975) for tax jurisdiction X, but rather on the Schedule A
that otherwise would be included as revenue by a constituent (Form 8975) for tax jurisdiction Y.
entity. Line 5. Enter the aggregate amount of the stated capital of
For a constituent entity that is an exempt organization, the constituent entities listed in Part II.
revenue means only revenue that is reflected in unrelated The stated capital of a permanent establishment must be
business taxable income. See Regulations section reported in the tax jurisdiction of residence of the legal entity
1.6038-4(d)(3)(ii). of which it is a permanent establishment unless there is a
Line 2. Enter the aggregate profit or loss before income tax defined capital requirement in the permanent establishment
of the constituent entities listed in Part II. tax jurisdiction for regulatory purposes.
Consistent with the definition of revenue, profit or loss Line 6. Enter the aggregate of total accumulated earnings of
before income tax does not include payments received from the constituent entities listed in Part II. However, the
other constituent entities in your group that are treated as accumulated earnings of a permanent establishment are
dividends in the payor's tax jurisdiction. considered those of the legal entity of which it is a permanent
establishment and should be reported on the Schedule A
Note. An amount representing all or part of a constituent (Form 8975) for the tax jurisdiction of the legal entity owner.
entity's profit that is required or permitted for financial Line 7. Enter the aggregate number of employees on a
reporting purposes to be included in the profit before tax of full-time equivalent basis of the constituent entities listed in
another constituent entity in the group should be treated in Part II. The number of employees may be reported as of the
the same way as dividends from other constituent entities year-end, on the basis of average employment levels for the
and excluded from revenue and profit or loss before income year, or on any other basis consistently applied across tax
tax. This instruction does not apply where a constituent entity jurisdictions of your group and from year to year.
includes in profit before tax for financial reporting purposes
an amount representing all or part of the profit of another Reasonable rounding or approximation of the number of
constituent entity in the group that is fiscally transparent. employees is permissible, provided that such rounding or
approximation does not materially distort the relative
Line 3. Enter the aggregate amount of income tax paid on a distribution of employees across the various tax jurisdictions
cash basis to all tax jurisdictions by the constituent entities of your group. Consistent approaches should be applied from
listed in Part II and any taxes withheld on payments received year to year and across entities.
by the constituent entities listed in Part II.
Line 8. Enter the aggregate of the net book value of tangible
Taxes paid should include taxes paid in cash by a assets of all the constituent entities listed in Part II. For
constituent entity listed in Part II to its tax jurisdiction and to

Instructions for Form 8975 (Rev.12-2020) -5-

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purposes of this schedule, tangible assets do not include • CBC502 Holding or managing intellectual property
cash or cash equivalents, intangibles, or financial assets. • CBC503 Purchasing or procurement
For permanent establishments, assets should be reported • CBC504 Manufacturing or production
on the Schedule A (Form 8975) for the tax jurisdiction in • CBC505 Sales, marketing, or distribution
which the permanent establishment is located. • CBC506 Administrative, management, or support services
• CBC507 Provision of services to unrelated parties
Part II—Constituent Entity • CBC508 Internal group finance
• CBC509 Regulated financial services
Information • CBC510 Insurance
In this section, you will provide constituent entity information • CBC511 Holding shares or other equity instruments
for your group regarding the constituent entities that have the • CBC512 Dormant
tax jurisdiction indicated in Part I. You should complete a row • CBC513 Other
for each constituent entity providing the information indicated Those that do not file electronically are limited to indicating
below. a maximum of three main business activities. However, if you
Line 1. Enter the full legal name of the constituent entity, feel this does not properly reflect the main businesses of a
including the domestic designation for the legal form, as constituent entity, you may use Part III, Additional
indicated in its articles of incorporation or any similar Information, on the appropriate Schedule A (Form 8975) to
document. If the constituent entity is a permanent enter additional codes and explain.
establishment, the naming convention to use is the name of Line 5b. If you entered the code for “Other” on line 4a,
the constituent entity of which the permanent establishment describe the “Other” business activity.
would be a part (if it were not its own constituent entity),
followed by “- (PE).” For instance, if XYZ Corp has a Part III—Additional Information
permanent establishment, that permanent establishment’s Briefly describe the sources of data used in preparing Parts I
name would be “XYZ Corp - (PE).” and II of the Schedule A (Form 8975). The description should
If filing electronically, the address of the constituent entity be sufficient to enable an understanding of the source of
may also be provided. each item of information supplied on the Schedule A (Form
Line 2. Enter the entity role used by the constituent entity as 8975). The source(s) of data could include consolidation
one of the following values. reporting packages, separate entity financial statements,
• CBC801 Ultimate Parent Entity regulatory financial statements, tax reporting records, or
• CBC802 Reporting Entity internal management accounts reports. If a change is made
• CBC803 Both (Ultimate Parent Entity and Reporting Entity) to the source of data used from year to year, explain the
If the roles above do not apply to the constituent entity role, reasons for the change and its consequences.
leave blank. Additionally, you can enter any relevant information or
Line 3. Enter the tax identification number (TIN), if any, used explanation that you deem necessary or that would facilitate
for the constituent entity by the tax administration in the tax the understanding of the information provided in Parts I and
jurisdiction of residence. The TIN is a mandatory field and II. The information may or may not relate to a specific
must be entered for each constituent entity. If the constituent constituent entity. The information may be used to explain
entity does not have a TIN, then enter “NOTIN.” the tax jurisdiction financial and employee information in Part
I. You can use the item reference codes listed next to
If filing electronically, one or more entity identification
indicate if the additional information relates to a specific item
numbers (IN), such as a company registration number, can
in Part I.
be provided, along with the IN’s issuer country and type.
• CBC601 Revenues—unrelated party
Line 4. Using the two-letter code from the list at IRS.gov/ • CBC602 Revenues—related party
CountryCodes, enter the tax jurisdiction in which the • CBC603 Revenues—total
constituent entity is organized or incorporated if different from • CBC604 Profit or loss
the tax jurisdiction of residence. However, see Tax • CBC605 Income tax paid
jurisdiction under Part I—Tax Jurisdiction Information, earlier, • CBC606 Income tax accrued
for codes that are not allowed. • CBC607 Stated capital
Line 5a. Identify the nature of the main business activity of • CBC608 Accumulated earnings
the constituent entity in the relevant tax jurisdiction by • CBC609 Number of employees
selecting at least one of the following codes or categories. • CBC610 Tangible assets
• CBC501 Research and development

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.

-6- Instructions for Form 8975 (Rev.12-2020)

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The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Form 8975 and Schedule A (Form 8975) . . . . . . . . . . . . . . . . . . . .    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.

Instructions for Form 8975 (Rev.12-2020)                                     -7-

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