There is no provision for group taxation in Macau SAR.
A taxpayer that is considered the ultimate parent entity of an MNE would be classified as a Group A taxpayer and would be required to maintain proper books and records for tax filing purposes. An ultimate parent entity would be required to fulfil the Country-by-Country Reporting (CbCR) filing obligation if the total revenue in its consolidated financial statements for the past financial year exceeds a certain threshold (currently set at MOP 7 billion). The CbCR will be exchanged with other tax jurisdictions through automatic tax information exchange under the multilateral Convention on Mutual Administrative Assistance in Tax Matters.
There is no thin capitalisation provision in the Macau tax regime.
Controlled foreign companies (CFCs)
There are no CFC rules in the Macau tax regime.