The Inclusive Framework which is collaborating on the implementation of the OECD’s Base Erosion and Profit Shifting (BEPS) action plan has released information on the domestic legal frameworks for country-by-country reporting (CBCR) around the world, providing a high level snapshot for tax administrations and multinational companies as to the outline requirements
The details on different jurisdictions’ legal frameworks for CBCR include the status of the legislation, the first reporting periods, the availability of surrogate filing and voluntary filing, and whether local filing can be required.
This will be updated as Inclusive Framework members, who number more than 100 countries, continue to finalise their legal frameworks. 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 CBCR reports between tax administrations.
Additional interpretive guidance on the CBCR reporting standard has also been published, relating to instances where a notification to the tax administration may be required to identify the reporting entity within a multinational group.
The guidance confirms that if such notifications are required, jurisdictions have flexibility as to the due date for such notifications. The OECD says this may be particularly relevant during the transition period where jurisdictions are still completing their implementation of CBCR, as multinational groups may not yet have the necessary information to submit their notifications.
In addition, the guidance confirms that jurisdictions may wish to consider other transitional relief for multinational groups with respect to these notifications, which would also be consistent with the minimum standard.
Country-specific information on CBCR implementation is here.
Additional guidance on the implementation of CBCR: BEPS Action 13 is here.