OECD Releases Guidance on the Implementation of CbC Reporting

The OECD has released guidance on implementing country-by-country (CbC) reporting,  as set out in Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting” of the base erosion and profit shifting (BEPS) project. 

Country-by-Country Reporting

The CbC reporting, under which MNEs will be required to provide information about their economic activity within the MNE group on an annual basis, is one of the key priorities of OECD in addressing BEPS risks. The aim of the guideline is to set out:

  1. Transitional filing options for MNEs that voluntarily file in the Parent jurisdiction;
  2. Guidance on the application of CbC reporting to investment funds;
  3. Guidance on the application of CbC reporting to partnerships; and
  4. The impact of exchange rate fluctuations on the agreed EUR 750 million filing threshold for MNE groups.

Consistent Implementation

The OECD has stressed the importance of consistent and swift implementation of CbC reporting. The guidance has informed that multinational groups are already making preparations for CbC reporting, and dialogue between governments and business is a critical aspect of ensuring that CbC reporting is implemented consistently across the globe. "Consistent implementation will not only ensure a level playing field, but also provide certainty for taxpayers and improve the ability of tax administrations to use CbC reports in their risk assessment work," the guidance informed.

OECD Will Provide Further Information

A short 10-page guidance has further informed that the OECD will provide information on country specific aspects of CbC implementation, including the effective dates of CbC legal frameworks, local filing and surrogate filing mechanisms, and identifying the agreements for exchange of CbC reports that are in effect.

Sources: OECD - Press Release, OECD - Guidance on the Implementation of CbC Reporting  


Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.

Copyright © 2017
Transfer Pricing Associates BV.
All rights reserved.

H.J.E. Wenckebachweg 210
1096 AS Amsterdam
T: +31 20 462 3530
E: info@tpa-global.com
I: www.tpa-global.com