Country by Country Reporting: An overview and comparison of initiatives

CbyCR: An overview and comparison of initiatives

OECD released the final country by country reporting template under the Base Erosion and Profit Shifting (BEPS) Action Plan. This paper has been updated to reflect these developments.

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CbyC Reporting

Following on from the paper dated July 2014, there have been a number of updates to the requirements previously set out. Most notably the OECD released the final country by country reporting (CbyC) template under the Base Erosion and Profit Shifting (BEPS) Action Plan.


There are now a number of frameworks both legislative and voluntary, that have been implemented or are being considered for implementation. Initially these focused on the extractives sector, but more recent proposals are expected to impact on all industries and sectors.

The initiatives discussed in this paper cover:

  • Action 13 of the OECD’s BEPS (Base Erosion and Profit Shifting) Action Plan regarding country by country reporting and transfer pricing documentation.
  • Capital Requirements Directive IV (CRD IV).
  • EU Accounting Directive: Chapter 10.
  • Dodd Frank Act: Section 1504.
  • Extractive Industries Transparency Initiative (EITI).


Country by country reporting was initially focused on a few select sectors, but given the requirements from the OECD, this is now a pressing issue for all multinationals. Companies will need to consider the level of resources and costs involved in gathering the data, the ease of gathering the data and potential system changes and how technology can assist. The requirements for a form of assurance over the process will need to be considered.

Due to the risk of the information being misinterpreted, providing an accompanying narrative and articulating the tax position, will assist in making the information as useful as possible to the reader. The tax transparency debate is constantly evolving and companies should be actively involved in shaping this debate, as well as keeping abreast of proposals and how this may impact them.

© 2017 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

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