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Country-by-Country Reporting

Country-by-Country Reporting

The latest information on the EU's initiatives on public and non-public CBCR.

The latest information on the EU's initiatives on public and non-public CBCR.

The latest information on the EU’s initiatives on public and non-public CBCR.


Tax transparency is here to stay. As anyone involved in the tax arena will be aware, there has been a paradigm shift in the global tax landscape which has resulted in public and political pressure for action to tackle perceived harmful tax practices, particularly by corporate entities. The OECD and G20 has been working to bring together over 100 countries to adopt a coordinated package of 15 actions as part of its work on Base Erosion and Profit Shifting (BEPS). This includes action 13, which introduced a CBCR framework and template reporting mechanism for multi-national enterprises (MNEs) to share information with the tax authorities in each of the countries in which they have a tax presence. See KPMG’s dedicated website on the OECD/G20 work on such ‘non-public CBCR’.

‘Non-public’ CBCR will certainly help tax authorities gain a better understanding of the overall tax picture of an MNE business and structure, and help ensure better coordination between authorities to prevent double non-taxation. However, one other key motivation of institutions such as the EU in their work around tax transparency, is to ensure public accountability and transparency. Therefore, in parallel with the work being done by the OECD on the ‘non-public’ CBCR, the EU Commission has been working on designing ‘public’ CBCR rules. 

Public vs. non-public CBCR

Public CBCR brings additional considerations and concerns to be weighed against the perceived benefits. For multinationals, the extent to which the scales tip either way in this balance will determine whether the final rules will lead to additional compliance because of different data points, whether it will lead to a loss of competitiveness through disclosure of confidential business information or by going further than other international norms, or whether it will lead to reputational damage through misinterpretation of ‘one-size-fits-all’ disclosure formats. Such issues can only be properly evaluated on the basis of a sound understanding of what the different rules say and how they interact with each other. See here for KPMG’s EU Tax Centre’s report and comparative overview on CBCR from an EU perspective, as an initial guide for carrying out such an evaluation.

KPMG insights into CBCR


  • KPMG’s response to the EU public consultation on further corporate transparency (search for KPMG in the third column: “Name of your organisation”)
  • KPMG Institutes: BEPS – tax transparency website
  • KPMG’s BEPS Action 13 country implementation

Public CBCR

  • ETF 277: EU Commission proposes public Country-by-Country Reporting

Non-public CBCR 

  • TaxNewsFlash alert on the OECD report on status of BEPS project (25 July 2016)
  • TaxNewsFlash alert on OECD “tax talks” event which included BEPS status update (12 July 2016)
  • TaxNewsFlash alert on the OECD new inclusive framework on BEPS implementation (30 June 2016)
  • TaxNewsFlash alert on OECD guidance on implementation of CBCR (29 June 2016)
  • TaxNewsFlash alert on additional signatories to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (28 June 2016)
  • ETF 275: ECOFIN agreement on the proposed non-public CBCR requirements
  • ETF 268: ECON Committee report on corporate tax

Official documentation and resources


  • EU Commission website on company reporting

Non-public CBCR
  • EU Council Directive 2016/881 (PDF 385 KB) (amending Directive 2011/16/EU) as regards mandatory exchange of information in the field of taxation
  • The OECD maintains an up to date list (PDF 206 KB) of signatories on Action 13 BEPS
  • Final US country-by-country reporting regulations (PDF 250 KB)

Public CBCR

  • EU Commission webpage on Public Country-by-Country Reporting / Corporate tax transparency
  • EU Commission proposal (PDF 336 KB) for amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches


How KPMG can help and who to contact

Glossary of abbreviations

  • CE – Constituent Entity
  • CBCR – Country-by-country reporting
  • MNE Group – Multinational Entity (group)
  • UPE – Ultimate Parent Entity
  • OECD – Organisation for Economic Co-operation and Development
  • BEPS – the OECD’s Base Erosion and Profit Shifting project
  • PE – Permanent Establishment

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