Base erosion and profit shifting

Country-by-Country Reporting: Handbook on Effective Implementation


Country-by-Country Reporting Handbook on Effective Implementation

Published: 29 September 2017


Download the report (PDF)


Country-by-Country (CbC) Reporting is one of the four minimum standards under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project to which over 100 countries have committed, covering the tax residence jurisdictions of nearly all large MNE groups. Where CbC Reporting is implemented effectively, and in line with the conditions set out in the BEPS Action 13 Report, it will give tax authorities unprecedented access to information on the global allocation of an MNE group's revenue, profit, tax and other attributes for high level transfer pricing risk assessment and the assessment of other BEPS-related risks.

This handbook is a practical guide to assist countries in implementing CbC Reporting into their domestic law, taking into account:

  • key factors that countries should consider in introducing a domestic legal framework for the filing and use of CbC Reports;
  • issues concerning the implementation and operation of an international framework for the exchange of CbC Reports;
  • operational aspects of CbC Reporting, including mechanisms to identify entities required to file CbC Reports in a country, the handling of CbC Reports and the importance of effective sanctions for non-compliance; and
  • practical issues including the importance of guidance to taxpayers and tax authority staff, engaging with stakeholders and providing training for staff who will deal with CbC Reports.


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