CbC reporting by surrogate or constituent entity

A CbC report made by a surrogate parent entity or constituent entity on behalf of the ultimate parent entity shall be– (a) taken to have been made by that ultimate parent entity, unless the ultimate parent entity proves that the return was made without the ultimate parent entity’s authority; (b) in accordance with the OECD’s guidance on currency fluctuations in respect of the threshold required for filing of that CbC Mutual Administrative Assistance in Tax Matters [CAP. 103:03 29 Schedule 2.