Country-by-Country Reporting – Compilation of 2021 Peer Review Reports
Inclusive Framework on BEPS: Action 13
Under the Action 13 Minimum Standard of the OECD/G20 BEPS Project, jurisdictions have
committed to foster tax transparency by requesting the largest multinational enterprise
groups (MNE Groups) to provide the global allocation of their income, taxes and other
indicators of the location of economic activity. This unprecedented information on
MNE Groups’ operations across the world has boosted tax authorities’ risk assessment
capabilities. The Action 13 Minimum Standard was translated into specific terms of
reference and a methodology for the peer review process. The peer review of the Action
13 Minimum Standard has completed four annual reviews in 2017, 2018, 2019 and 2020.
These cover the three key areas under review: the domestic legal and administrative
framework, the exchange of information framework, and the confidentiality and appropriate
use of Country-by-Country (CbC) reports. This 2021 annual peer review report reflects
the outcome of the fourth review which considered all aspects of implementation. It
contains the review of 132 member jurisdictions of the OECD/G20 Inclusive Framework
on BEPS which provided legislation or information pertaining to the implementation
of CbC Reporting.
Published on October 18, 2021Also available in: French
Ce recueil inclut les versions en français des rapports d’examen des pays francophones suivants : la Belgique, le Bénin, le Cameroun, le Canada, la Côte d’Ivoire, Djibouti, la France, le Gabon, Haïti, le Luxembourg, le Maroc, Maurice, la Principauté de Monaco, la République démocratique du Congo, le Sénégal, les Seychelles, la Suisse et la Tunisie.
Over 100 jurisdictions have already introduced legislation to impose a filing obligation on MNE groups, covering practically all MNE Groups with consolidated group revenue at or above the threshold of EUR 750 million. Remaining Inclusive Framework members are working towards finalising their domestic legal frameworks with the support of the OECD.
Where legislation is in place, the implementation of CbC Reporting has been found largely consistent with the Action 13 minimum standard.
A large number of recommendations made in the first three peer review phases have now been addressed and these recommendations have been removed.
More than 3000 bilateral relationships for the exchange of CbC reports are now in place.
The Country-by-Country Reporting requirements form one of the four BEPS minimum standards. Each of these minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the Action 13 minimum standard on CbC reporting, and to participating in the peer review.