Base erosion and profit shifting

Progress continues in strengthening tax transparency through Country-by-Country reporting


25/09/2023 – Under OECD/G20 Inclusive Framework on BEPS, over 140 jurisdictions have committed to implement minimum standards to improve the taxation of multinational enterprises (MNEs) worldwide. Today, the OECD has released the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs, demonstrating strong progress in international efforts.


The BEPS Action 13 minimum standard on Country-by-Country reporting (CbC) requires tax administrations to collect and share detailed information on all large MNEs doing business in their country. Information collected includes the amount of revenue reported, profit before income tax, and income tax paid and accrued, as well as the stated capital, accumulated earnings, number of employees and tangible assets, broken down by jurisdiction.


The sixth annual peer review of BEPS Action 13 considers implementation of the CbC reporting minimum standard by jurisdictions as of April 2023 and covers 136 Inclusive Framework members. Highlights include:

  • Over 110 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 five peer review phases have now been addressed and these recommendations have been removed.
  • More than 3 000 bilateral relationships for the exchange of CbC reports are now in place.


The BEPS Action 13 peer review is an annual process and the next peer review report will be released in the third quarter of 2024.



Media queries should be directed to Mark Johnson, Co-Head of the Tax Certainty Unit, International Co-operation and Tax Administration Division of the OECD Centre for Tax Policy and Administration (CTPA) or to the CTPA Communications Office.


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