As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), the OECD released a consultation document on the review of Country-by-Country Reporting (CbCR). The OECD invites public comments on the Review of the BEPS Action 13 minimum standard.
Action 13 of the OECD/G20 Base Erosion and Profit Shifting Project (BEPS Action 13) established a three-tiered standardised approach to transfer pricing documentation, comprising of a Master File, a Local File and a CbCR. Of these documents, only the CbCR is covered by the BEPS Action 13 minimum standard, which all members of the Inclusive Framework are committed to implement. The BEPS Action 13 report also included a mandate for a review of the BEPS Action 13 minimum standard, to be completed by the end of 2020 (the 2020 review) which would take into account matters including:
- whether modifications to the content of CbCRs should be made, to require the reporting of additional or different data;
- the appropriateness of the applicable revenue threshold;
- the effectiveness of filing and dissemination mechanisms; and
- the implementation of the BEPS Action 13 implementation package.
The public consultation document forms an intrinsic and essential part of this review, as a mechanism to obtain feedback from all stakeholders. Specific questions upon which comments are sought are set out in each chapter of the document. Chapter 1 contains general topics concerning the implementation and operation of BEPS Action 13. Chapter 2 contains topics concerning the scope of CbCR. Finally, chapter 3 contains topics concerning the content of a CbCR.
The Inclusive Framework welcomes comments on all aspects of the BEPS Action 13 report, but specifically invites comments on the questions raised throughout the public consultation document. Interested parties are invited to send their comments no later than March 6, 2020.
Public consultation meeting
The public consultation meeting on the 2020 review of BEPS Action 13 will be held at the OECD Conference Centre in Paris on March 17, 2020. The public consultation meeting will focus on the key questions identified in the consultation document and raised in the written submissions received as part of the consultation process.