The OECD has released two sets of guidance to give greater certainty to tax administrations and multinational groups on the implementation and operation of country-by-country reporting (CBCR), which is action 13 of its Base Erosion and Profit Shifting (BEPS) plan
The OECD's inclusive framework on BEPS has updated existing guidance on CBCR to address three issues.
These are the definition of revenues; the treatment of multinational groups with a short accounting period; and the treatment of the amount of income tax accrued and income tax paid.
The published document contains the complete set of interpretative guidance related to CBCR so far and will continue to be updated with any further guidance that may be agreed.
Guidance has also been released on the appropriate use of the information contained in CBRC. This includes guidance on the meaning of ‘appropriate use’, the consequences of non-compliance with the appropriate use condition and approaches that may be used by tax administrations to ensure compliance with this.
Guidance on the implementation of country by country reporting, BEPS Action 13 is here.
BEPS action 13 on country by country reporting appropriate use of information is here.
Report by Pat Sweet
