Base erosion and profit shifting

OECD releases CbC reporting implementation status and exchange relationships between tax administrations


04/05/2017 - Today, another important step was taken to implement Country-by-Country Reporting in accordance with the BEPS Action 13 minimum standard, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports ("the CbC MCAA"). With over a year still to go before the first exchanges of CbC Reports take place, more than 700 automatic exchange relationships have now been established among jurisdictions committed to exchanging CbC Reports as of 2018, including those between EU Member States under EU Council Directive 2016/881/EU.


More jurisdictions will nominate partners with which they will undertake the automatic exchange of CbC Reports under the CbC MCAA in the coming months. Some jurisdictions also continue to work towards agreeing bilateral competent authority agreements for the automatic exchange of CbC Reports with specific partners under Double Tax Conventions or Tax Information Exchange Agreements. Regular updates will be published on the OECD website on exchange relationships to provide clarity for MNE Groups and tax administrations.


The full list of automatic exchange relationships that are now in place is available, together with an update on the implementation of the domestic legal framework for CbC Reporting in jurisdictions; on jurisdictions that will permit surrogate filing and voluntary parent surrogate filing; and on steps that are being taken to address concerns about local filing being applied before the end of 2017.


Today's wave of activations of CbC Reporting exchange relationships is an important step towards the timely implementation of Country-by-Country Reporting and reflects the commitment of jurisdictions around the world to the fight against base erosion and profit shifting.



Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 6 26 30 49 23) or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 6 21 63 27 67).


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