Base erosion and profit shifting

OECD releases further guidance for tax administrations and MNE Groups on Country-by-Country reporting (BEPS Action 13)


06/04/2017 - The Inclusive Framework on BEPS has released additional guidance to provide essential information that will give certainty to tax administrations and MNE Groups alike on implementation of Country-by-Country (CbC) reporting (BEPS Action 13).


The additional guidance clarifies several interpretation issues related to the data to be included in the CbC report as well as to the application of the model legislation contained in the Action 13 report, to assist jurisdictions with the introduction of consistent domestic rules. Five specific issues are addressed in this guidance: the definition of revenues; the accounting principles/standards for determining the existence of and membership in a group; the definition of total consolidated group revenue; the treatment of major shareholdings; and the definition of related party for purposes of completing Table 1 of the CbC report.


The complete set of guidance relating to CbC reporting is presented in the guidance document, which will be updated for any further guidance that may be published.



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), 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).


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