Printable Form 2026

IRS Form 8975 – Country by Country Report

IRS Form 8975 – Multinational enterprises (MNEs) with significant global operations must comply with U.S. country-by-country (CbC) reporting requirements under IRC Section 6038. IRS Form 8975 (Country by Country Report) and its Schedule A (Form 8975) — officially titled Tax Jurisdiction and Constituent Entity Information — provide tax authorities with aggregated data on revenues, profits, taxes, and activities by jurisdiction.

This detailed, SEO-optimized guide draws directly from official IRS sources (Form 8975, Schedule A, and Instructions, all Rev. December 2020, still current as of 2026) to help U.S. ultimate parent entities understand requirements, filing steps, and exact data needed.

What Is IRS Form 8975 and Schedule A?

Form 8975 serves as the cover sheet for CbC reporting. It identifies the reporting entity, reporting period, and number of attached Schedules A.

Schedule A (Form 8975) is the core component: one separate Schedule A must be completed for each tax jurisdiction in which the U.S. MNE group has one or more resident constituent entities (including the United States and any “stateless” entities).

The reporting standard follows OECD CbC guidelines but uses IRS-specific formats and codes for U.S. compliance.

Who Must File Form 8975 and Schedule A?

U.S. persons who are the ultimate parent entity of a U.S. MNE group must file if the group’s annual consolidated revenue in the preceding reporting period equals or exceeds $850 million.

  • A U.S. territory ultimate parent entity can designate a U.S. business entity to file.
  • No filing required if revenue threshold is not met.
  • “U.S. MNE group” = ultimate parent entity + all business entities required to consolidate under U.S. GAAP (with specific exclusions).

Reporting period = the 12-month period of the group’s applicable financial statement ending with or within the ultimate parent entity’s tax year (or the tax year itself if no annual statement exists).

File Form 8975 + all Schedules A with the ultimate parent entity’s timely-filed income tax return (e.g., Form 1120, 1065, 1120-S, 990-T, etc.). It cannot be filed standalone.

Why Is CbC Reporting Required?

CbC reports help tax authorities assess transfer pricing risks and ensure fair taxation of multinational profits. The IRS automatically exchanges these reports with foreign jurisdictions under competent authority arrangements (see the IRS Jurisdiction Status Table for exchange status).

Special rules apply to certain national security contractors under Notice 2018-31 (simplified filing allowed).

How to File: Electronic vs. Paper?

  • Electronic (strongly encouraged): Attach in approved XML format via Modernized e-File (MeF) when the return is e-filed.
  • Paper: Attach to the paper return and mail a copy of only page 1 of Form 8975 to:
    Internal Revenue Service, Mailstop 4950, 1973 N. Rulon White Blvd., Ogden, UT 84201.
  • Amended reports require an amended tax return with the full set of forms and the “Amended Report” box checked.

Penalties under IRC Section 6038(b) apply for failure to file or incomplete reporting.

Detailed Breakdown of Schedule A (Form 8975)

Part I – Tax Jurisdiction Information

Complete one row per tax jurisdiction using the two-letter OECD country code (e.g., “US” for United States; “X5” for stateless). Full list available at IRS.gov/CountryCodes (with exceptions noted in instructions).

All amounts reported in U.S. dollars.

Columns include:

  1. Revenues
    • (a) Unrelated party
    • (b) Related party (excludes certain dividends/distributions)
    • (c) Total
  2. Profit (loss) before income tax (aggregated, with specific exclusions)
  3. Income tax paid (on cash basis) – to all jurisdictions
  4. Income tax accrued – current year (current tax expense only; no deferred taxes)
  5. Stated capital
  6. Accumulated earnings
  7. Number of employees (full-time equivalents; reasonable rounding OK if consistent)
  8. Tangible assets other than cash and cash equivalents
    • (a) Unrelated party
    • (b) Related party
    • (c) Total (net book value)

Special rules for permanent establishments (PEs): Treat qualifying PEs as separate constituent entities and report taxes/assets in the PE’s jurisdiction (not the owner’s).

Part II – Constituent Entity Information

List every constituent entity resident in the tax jurisdiction named in Part I.

For each entity provide:

  1. Full legal name (add “- (PE)” for permanent establishments)
  2. Entity role (use CBC codes):
    • CBC801 – Ultimate Parent Entity
    • CBC802 – Reporting Entity
    • CBC803 – Both
    • Blank if neither
  3. TIN (or “NOTIN” if none)
  4. Tax jurisdiction of organization/incorporation if different from residence (two-letter code)
  5. Main business activities (select from CBC501–CBC513 codes; paper filers limited to 3 per entity; describe “Other” in 5b; add extras in Part III if needed)

Part III – Additional Information

Explain:

  • Sources of data used (consolidation packages, separate financial statements, tax records, etc.)
  • Any changes in data sources from prior years
  • Exchange rates if not U.S. GAAP
  • Clarifications for any line items (use reference codes like CBC601 for revenues—unrelated party)
  • Any other relevant explanations

This section is crucial for transparency and to avoid follow-up questions from the IRS or exchange partners.

Key Definitions (from IRS Instructions)

  • Ultimate Parent Entity: The top U.S. business entity that consolidates others under U.S. GAAP and is not itself owned/controlled by another consolidator.
  • Constituent Entity: Any business entity (including disregarded entities and qualifying PEs) in the U.S. MNE group.
  • Tax Jurisdiction: A country or territory with independent taxing authority.
  • Stateless Entities: Reported on a dedicated “X5” Schedule A.

Common Questions About Form 8975 Schedule A

Do I need a Schedule A for the United States?
Yes — at minimum, one for the U.S. and one for any stateless entities.

What if an entity has no TIN?
Enter “NOTIN”.

Can I file early or for prior years?
Yes, under Rev. Proc. 2017-23 for transitional periods (with specific notification rules).

How do I handle U.S. LLCs or partnerships?
Depends on check-the-box elections and ownership — see instructions for detailed treatment (often treated as U.S. resident or stateless).

Tips for Accurate Completion

  • Maintain robust records supporting all numbers (no formal reconciliation to tax returns or GAAP statements is required, but consistency matters).
  • Use the exact OECD CbC activity and role codes.
  • For paper filers using continuation sheets, clearly label jurisdiction and page numbers.
  • Review the full Instructions for Form 8975 and Schedule A (PDF) before filing.

Stay Compliant in 2026 and Beyond

CbC reporting remains a key BEPS (Base Erosion and Profit Shifting) compliance obligation. While the form and instructions have not changed since the December 2020 revision, always verify the latest at irs.gov/Form8975 or consult a qualified international tax advisor.

Official Resources:

Properly completed Form 8975 Schedule A helps multinational groups demonstrate transparency while minimizing transfer pricing scrutiny. If your U.S. MNE group meets the $850 million threshold, ensure this filing is on your compliance calendar.