Érosion de la base d'imposition et transfert de bénéfices

OECD releases further guidance for tax administrations and MNE Groups on Country-by-Country reporting


23/12/2019 - The Inclusive Framework on BEPS has released additional interpretative guidance to give greater certainty to tax administrations and MNE Groups on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13). The new guidance makes clear that, under the BEPS Action 13 minimum standard, the automatic exchange of CbC reports filed under local filing rules is not intended.


The complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far is presented in the document released today. This will continue to be updated with any further guidance that may be agreed.


In addition, a summary of CbC reporting notification requirements in Inclusive Framework member jurisdictions has been posted on the OECD website. The release of this summary will help MNE Groups in complying with notification requirements in different jurisdictions where they have constituent entities.



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 1 45 25 98 92), or Matt Andrew, Senior Tax Advisor in the Tax Treaty, Transfer Pricing and Financial Transactions Division (+33 1 85 55 45 78).


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