The OECD advises that there has been strong progress in improving the taxation of multinational enterprises (MNEs) worldwide, according to the latest round of peer reviews of Country-by-Country (CbC) initiative. In reporting on the results of this review, the OECD also notes work progresses on the 2020 review of the CbC reporting minimum standard, which it expects to be completed this year.

Background

The OECD's annual peer reviews are intended to analyze how tax administrations are using CbC reports to assess various risks, including transfer pricing risks. The OECD says this work will help jurisdictions use CbC reports more effectively, enabling them to identify areas where the tax risks posed by MNE Groups are low and to instead focus resources on those issues where risk is greatest.

CbC progress

This third annual peer review covers 131 jurisdictions, including Canada, and considers implementation of the CbC reporting minimum standard by jurisdictions as of April 2020. The OECD reports that the review has found that:

• Over 90 jurisdictions have introduced legislation to impose a CbC filing obligation on MNE groups, such that practically all MNEs that are over the EUR 750 million threshold for filing are now covered
• Implementation is largely consistent with BEPS Action 13
• Jurisdictions have acted on prior recommendations from earlier peer reviews
• Over 2500 exchange relationships are now in place

Canada's results

According to the peer review, Canada meets all the terms of reference for each of the three areas subject to review:

• The domestic legal and administrative framework
• The exchange of information framework
• Appropriate use of CbC reports

As a result, the peer review does not identify any recommendations for Canada.

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