OECD: New methodology for peer review of BEPS Action 13 country-by-country reporting

OECD: BEPS Action 13 country-by-country reporting

The Organisation for Economic Cooperation and Development (OECD) today released a new methodology for peer review of base erosion and profit shifting (BEPS) Action 13 country-by-country (CbC) reporting.

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According to today’s OECD release, the report today forms the basis on which the continuing BEPS Action 13 peer review processes will be undertaken. The Action 13 standard on CbC reporting—like the other four BEPS minimum standards—is subject to peer review to determine there is timely and accurate implementation. All members of the Inclusive Framework on BEPS have committed to implementing the minimum standards and participating in the peer reviews.

In October 2019, the Inclusive Framework extended the mandate for peer reviews beyond the original 2020 date. The documents released today form the basis on which the continuing BEPS Action 13 peer review processes will be undertaken.

Today’s OECD report [PDF 1.2 MB] (60 pages) includes the “Terms of Reference” (unchanged from the original mandate in 2017) setting out the criteria for assessing the implementation of the minimum standard, and the “Methodology” setting out the procedural mechanism by which jurisdictions will complete the peer review from 2020 onwards, including the process for collecting the relevant data, the preparation and approval of reports, the outputs of the review, and the follow-up process.

Background

CbC reporting is one of the four minimum standards of the BEPS project, and requires tax administrations to collect and share detailed information on all large multinational entities (MNEs) doing business in their jurisdiction. The CbC information includes the amount of revenue reported, the amount of profit before income tax, the amount of income tax paid and accrued, and the stated capital, accumulated earnings, number of employees, and tangible assets (reported by jurisdiction).

CbC reporting is intended to provide a level of transparency to tax administrations. As a result, tax administrations will have access to detailed information on all large MNEs doing business in their country.

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