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OECD: Update on BEPS implementation, country-by-country reporting

OECD: Update on BEPS implementation, CbC reporting

The Organisation for Economic Cooperation and Development (OECD) today announced the release of additional guidance on implementation of country-by-country (CbC) reporting under base erosion and profit shifting (BEPS) Action 13.


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The additional guidance addresses two specific issues: 

  • The definition of total consolidated group revenue
  • Whether non-compliance with the confidentiality, appropriate use, and consistency conditions constitutes systemic failure

Today’s OECD release states that the documents released today provide the complete set of guidance related to CbC reporting, as well as a compilation of the approaches adopted by member jurisdictions of the BEPS Inclusive Framework with respect to issues when the guidance allows for alternative approaches.

The Inclusive Framework for BEPS also approved updates to the results for “preferential tax regime” reviews by the Forum on Harmful Tax Practices (FHTP) in connection with BEPS Action 5. 

  • Two regimes of Barbados were found to be "potentially harmful" and Barbados committed to amend these regimes.
  • Canada's regime for international banking centres, determined to be "potentially but not actually harmful,” was abolished but with limited grandfathering.

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