OECD: Implementation package for BEPS CbyC reporting | KPMG | BE

OECD: Implementation package for BEPS country-by-country reporting

OECD: Implementation package for BEPS CbyC reporting

The Organisation for Economic Co-operation and Development (OECD) today released a package for implementation of a new country-by-country reporting plan developed under the OECD/G20 base erosion and profit shifting (BEPS) project.


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Read the country-by-country reporting implementation package [PDF 991 KB]


According to a related OECD release, the country-by-country reporting implementation package will facilitate “a consistent and swift implementation” of new transfer pricing reporting standards developed under Action 13 of the BEPS project. It will allow tax administrations to obtain a complete understanding of the way multinational enterprises structure their operations, while safeguarding the confidentiality of such information.

Country-by-country reporting requirements

The country-by-country reporting requirements will require multinational entities to provide aggregate information annually—in each jurisdiction where they do business—relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the group, as well as information about which entities do business in a particular jurisdiction and the business activities each entity engages in. 

  • The new implementation package consists of model legislation requiring the ultimate parent entity of a multinational group to file the country-by-country report in its jurisdiction of residence, including backup filing requirements when that jurisdiction does not require filing.
  • The package also contains three model competent authority agreements to facilitate the exchange of country-by-country reports among tax administration.
  • The model agreements are based on the Multilateral Convention on Administrative Assistance in Tax Matters, bilateral tax conventions and tax information exchange agreements (TIEAs).

The package was approved by the countries participating in the OECD/G20 BEPS project at the last meeting of the OECD Committee on Fiscal Affairs, held on 27-28 May, and follows from the publication of two reports:

  • Guidance on Transfer Pricing Documentation and Country-by-Country Reporting (September 2014)
  • Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting Proposals (February 2015)

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