CbC Reporting

Country-by-Country (CbC) reports contain valuable information on the global allocation of the income, taxes paid and the location of economic activity among tax jurisdictions in which an MNE group operates, for use in a high level transfer pricing risk assessment, assessment of other BEPS-related risks, and economic and statistical analysis, if appropriate. However, this information…

Action 13 of the OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) requires the development of “rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into consideration the compliance costs for business. The rules to be developed will include a requirement that MNEs provide all relevant governments with needed information…

The Convention on Mutual Administrative Assistance in Tax Matters (“the Convention“) was developed jointly by the OECD and the Council of Europe in 1988 and amended by Protocol in 2010. The Convention is the most comprehensive multilateral instrument available for all forms of tax co-operation to tackle tax evasion and avoidance. The Convention facilitates international co-operation for…

OECD Guidance on the Implementation of Country-by-Country Reporting contains a number of items of interpretative guidance prepared in response to questions raised by tax authorities and business on aspects of the BEPS Action 13 minimum standard. Several of these items of guidance provide flexibility for jurisdictions to take different approaches including, in particular: (i) whether…

The table below contains information on the domestic legal frameworks for Country-by-Country (CbC) reporting around the world. It provides a high-level snapshot for tax administrations and MNE Groups as to the first reporting periods, availability of surrogate filing including in the parent jurisdiction, and local filing. This table contains the information received from members so…

Ad. 1. Introduction All OECD and G20 countries have committed to implementing Country-by-Country reporting, as set out in the Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting”. Recognising the significant benefits that CbC reporting can offer a tax administration in undertaking high level risk assessment of transfer pricing and other BEPS related tax risks,…

From the tax period that began on January 1st, 2016, companies are required to report on country-by-country related party transactions. This obligation does not affect a large number of companies, but it does represent an important procedure for those that must submit the Country by Country (CBC) report. Ad. What is CbC? It is a…

Updated on January 2023. Ad.