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OECD: Consultation document on review of country-by-country reporting

OECD: Consultation document on review of CbC reporting

The Organisation for Economic Cooperation and Development (OECD) today released a public consultation document as part of the ongoing work of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) project.


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The OECD release includes an invitation for public comments on the review of the BEPS Action 13 minimum standard.


Action 13 of the BEPS project established a three-tiered standardised approach to transfer pricing documentation, including a country-by-country (CbC) report that provides details of a multinational entity (MNE) group’s revenues, profit before tax, tax accrued, and other information relevant to a high-level risk assessment, for each tax jurisdiction in which the MNE group has a constituent entity.

CbC reporting is one of four BEPS minimum standards which all members of the Inclusive Framework are committed to implementing.

The BEPS Action 13 report also included a requirement that a review of the CbC reporting ‎minimum standard be completed by the end of 2020.

Public consultation document

The public consultation document [PDF 748 KB] concerns matters for which input from stakeholders is requested in conducting the 2020 review. The public consultation document comprises three chapters:

  • Chapter 1 contains general topics concerning the implementation and operation of BEPS Action 13
  • Chapter 2 contains topics concerning the scope of CbC reporting
  • Chapter 3 contains topics concerning the content of a CbC report

Specific questions upon which comments are sought are set out in each chapter.

As noted in the OECD release, the public consultation document is based upon the mandate set out in the BEPS Action 13 report, and focuses on issues concerning the use of CbC reports by tax administrations for the purposes of a high-level transfer pricing risk assessment, the assessment of other BEPS-related risks, and economic and statistical analysis.

The Inclusive Framework on 31 January 2020 released a Statement on the Two-Pillar Approach to Address the Tax Challenges Arising From the Digitalisation of the Economy. Work on that approach may include consideration as to whether elements of the framework or principles underpinning CbC reporting may be used to support implementation and operation of Pillar 1 and/or Pillar 2, and input from stakeholders may be sought as part of that process. These matters are not considered in the public consultation document released today.

Comments are due no later than Friday, 6 March 2020.

The public consultation meeting on the 2020 review of BEPS Action 13 will be held on 17 March 2020 in Paris.

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