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OECD: Guidance for tax administrations, MNE groups on country-by-country reporting

OECD: Guidance for tax administrations, MNE groups

The Organisation for Economic Cooperation and Development (OECD) today announced guidance for use by tax administrations and multinational enterprise (MNE) groups with regard to country-by-country (CbC) reporting pursuant to base erosion and profit shifting (BEPS) Action 13.


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As noted in the OECD release, the additional interpretative guidance are intended to provide greater certainty to tax administrations and MNE groups on the implementation and operation of CbC reporting (BEPS Action 13). The new guidance clarifies that, under the BEPS Action 13 minimum standard, the automatic exchange of CbC reports filed under local filing rules is not intended.

Today’s announcement states that the complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued to date is included in the document released today, and it will continue to be updated with any future guidance.

Also, a summary of CbC reporting notification requirements in Inclusive Framework member jurisdictions has been provided by the OECD. The release of this summary is intended to help MNE groups comply with notification requirements in the different jurisdictions where they have constituent entities.

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