The additional guidance addresses two specific issues: how to treat an entity owned and/or operated by two or more unrelated multinational groups, and whether aggregated data or consolidated data for each jurisdiction is to be reported in table 1 of the country-by-country report.

This is the latest update to the BEPS action 13 report (Transfer Pricing Documentation and Country-by-Country Reporting) which provides a template for multinationals to report annually and for each tax jurisdiction in which they do business the information set out therein. This report is called the country-by-country report.

The BEPS action 13 report includes a implementation package, consisting of model legislation which could be used by countries to require the ultimate parent entity of a multinational to file the country-by-country report in its jurisdiction of residence including backup filing requirements, along with three model competent authority agreements that could be used to facilitate implementation of the exchange of country-by-country reports.

The OECD says that as jurisdictions have moved into the implementation stage, some questions of interpretation have arisen. In the interests of consistent implementation and certainty for both tax administrations and taxpayers, the inclusive framework on BEPS has decided to issue guidance to address certain key questions, which will be periodically updated.

Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 is here.