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OECD: Updated country-by-country reporting guidance; dividends received, employee numbers

OECD: Updated country-by-country reporting guidance

The Organisation for Economic Cooperation and Development (OECD) today announced the release of new guidance in a “question and answer” (Q&A) format regarding implementation of country-by-country (CbC) reporting pursuant to the base erosion and profit shifting (BEPS) Action 13. The updated guidance includes a complete set of CbC guidance issued to date.


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The new, updated guidance includes new Q&As on the treatment of dividends received and the number of employees to be reported in instances when a multinational entity (MNE) uses proportional consolidation in preparing its consolidated financial statements. The guidance is to apply prospectively. 

The updated guidance also clarifies that “shortened amounts” are not to be used in completing Table 1 of a CbC report. It provides a table that summarises existing interpretative guidance on the approach to be applied in cases of mergers, demergers and acquisitions. 

New CbC MCAA bilateral exchange relationships

Today’s OECD release also notes that a set of newly established bilateral exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC reports (CbC MCAA) were published with respect to Bermuda, Curaçao, Hong Kong (China), and Liechtenstein. 

In a separate release, the OECD further noted that Israel and Lithuania deposit their instruments of ratification for the Multilateral BEPS Convention.

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