30/11/2017 - The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13).
The additional guidance addresses a number of specific issues: how to report amounts taken from financial statements prepared using fair value accounting; how to treat a negative figure for accumulated earnings in Table 1; how to treat mergers/acquisitions/de-mergers; how to treat short accounting periods; and the definition of total consolidated group revenue.
Since the Action 13 Report was released, jurisdictions have made great efforts to establish the necessary domestic and international legal and administrative frameworks for the filing and exchange of CbC Reports in accordance with the Action 13 minimum standard and the global landscape for CbC Reporting by MNE groups is still evolving. This initial period may be challenging for both tax administrations and MNE groups seeking to be compliant with CbC Reporting, which may call for a pragmatic approach that takes into account best efforts made to comply with CbC related obligations. These challenges should diminish over time, as the global landscape for CbC Reporting becomes more settled and both tax administrations and MNE groups gain in experience.
The complete set of guidance related to CbC reporting issued so far is presented in the document released today. This will continue to be updated with any further guidance that may be agreed.
Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 08), Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 6 21 63 27 67), or Jefferson VanderWolk, Head of the Tax Treaty, Transfer Pricing, and Financial Transactions Division (+33 1 45 24 94 90).