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2016/10 OECD: BEPS guidance on country-by-country reporting, country-specific information on implementation

The Organisation for Economic Cooperation and Development (OECD) announced two new documents to support the global implementation of country-by-country (CbC) reporting under Action 13 of the base erosion and profit shifting (BEPS) project.


  • Key details of jurisdictions' domestic legal frameworks for CbC reporting

The details on jurisdictions' legal frameworks* for CBC reporting include the status of the legislation, first reporting period, availability of surrogate filling and voluntary filing, and whether local filing can be required. This will be updated as legal frameworks are finalized. Information will also be published in the coming months as to the Qualifying Competent Authority Agreements (QCAA) being put in place to facilitate the international exchange of CbC reports between tax administrations. 

  • Additional interpretive guidance on the CbC reporting standard

The additional interpretive guidance** relates to situations when a notification to the tax administration may be required to identify the reporting entity within a MNE group (as provided in Article 3 of the Model Legislation in the Action 13 Report). The interpretive guidance confirms that if notifications are required, jurisdictions will have flexibility as to the due date for such notifications—especially during the transition period when jurisdictions are still completing their implementation of CbC reporting because MNE groups may not yet have the necessary information to submit their notifications. The guidance also confirms that jurisdictions may wish to consider other transitional relief for MNE groups with respect to these notifications, which would also be consistent with the minimum standard.

The OECD concluded that additional guidance will be published "as necessary to support the swift, consistent, and global implementation of CbC reporting."


* Japan provides transition relief for the fiscal year commencing between 1 April 2016 and 31 March 2017 except the case of Systemic Failure.

** Liechtenstein: Confirmed by Parliament in November 2016. Currently, within the referendum period.

*** Turkey: In order to start the implementation, secondary regulations have to be in place, drafts are published but they are not officialy issued.​

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2016/10 OECD: BEPS guidance on country-by-country reporting, country-specific information on implementation​​