The OECD has released additional guidance on country-by-country (CbC) reporting.
Released on July 18, 2017, the OECD's new guidance addresses two specific issues. The first is how to treat an entity that is owned or operated by two or more unrelated multinational entity (MNE) groups. The second issue addressed is whether MNE groups should report aggregated data or consolidated data for each of the jurisdictions they operate in under Table 1 of the CbC report. According to the OECD, this additional guidance is intended to give tax administrations and MNE Groups "more certainty" as they begin to implement CbC reporting under Action 13 of the OECD's base erosion and profit shifting (BEPS) project.
The new CbC reporting standards were developed under BEPS Action 13. Action 13 proposes to tackle international tax base erosion and profit shifting by enhancing transparency for tax administrations by providing them with adequate information so that they can conduct proper transfer pricing risk assessments and examinations.
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Information is current to July 25, 2017. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500