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Country-by-Country Reporting – Updated Guidance from OECD

Country-by-Country Reporting – Updated Guidance

Additional interpretative guidance on CbC reporting aims to give greater certainty to tax administrations and MNE Groups.

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Sarah Norton

Director, B2B Tax Ps and As

KPMG in the UK

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The OECD/G20 Inclusive Framework on BEPS has released additional interpretative guidance on the implementation and operation of Country-by-Country (CbC) reporting to give greater certainty to tax administrations and multinational enterprise (MNE) Groups. A summary of common errors made by MNE Groups in preparing CbC reports has also been posted on the OECD website.

The new guidance, which is relevant to MNE Groups required to complete an annual CbC return, includes questions and answers on the following topics:

  • Common errors made by MNE groups in preparing CbC reports;
  • Information that must be provided with respect to the sources of data in Table 3;
  • The treatment of dividends received for the purposes of profit before tax, income tax accrued and income tax paid on Table 1;
  • Use of shortened/rounded amounts on Table 1;
  • Local filing;
  • Short or long accounting periods; and
  • Deemed listing provision where no securities exchange in a jurisdiction.

The complete set of guidance to date, including the latest guidance added in November 2019, can be found here. The OECD will continue to update this with any further guidance that may be agreed.

In addition, a summary of common errors made by MNE Groups in preparing CbC reports has also been posted on the OECD website. This summary will help MNE Groups in avoiding these errors and tax administrations in detecting them where they occur. This summary will be updated as further common errors, if any, are identified.

For further information please contact :

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