Country-by-Country Reporting

Country-by-Country Reporting

The latest information on the EU's initiatives on public and non-public CBCR.

The latest information on the EU's initiatives on public and non-public CBCR.

The latest information on the EU’s initiatives on public and non-public CBCR.

Overview

Tax transparency is here to stay. As anyone involved in the tax arena will be aware, there has been a paradigm shift in the global tax landscape which has resulted in public and political pressure for action to tackle perceived harmful tax practices, particularly by corporate entities. The OECD and G20 has been working to bring together over 100 countries to adopt a coordinated package of 15 actions as part of its work on Base Erosion and Profit Shifting (BEPS). This includes action 13, which introduced a CBCR framework and template reporting mechanism for multi-national enterprises (MNEs) to share information with the tax authorities in each of the countries in which they have a tax presence. See KPMG’s dedicated website on the OECD/G20 work on such ‘non-public CBCR’.

‘Non-public’ CBCR will certainly help tax authorities gain a better understanding of the overall tax picture of an MNE business and structure, and help ensure better coordination between authorities to prevent double non-taxation. However, one other key motivation of institutions such as the EU in their work around tax transparency, is to ensure public accountability and transparency. Therefore, in parallel with the work being done by the OECD on the ‘non-public’ CBCR, the EU Commission has been working on designing ‘public’ CBCR rules. 

Public vs. non-public CBCR

Public CBCR brings additional considerations and concerns to be weighed against the perceived benefits. For multinationals, the extent to which the scales tip either way in this balance will determine whether the final rules will lead to additional compliance because of different data points, whether it will lead to a loss of competitiveness through disclosure of confidential business information or by going further than other international norms, or whether it will lead to reputational damage through misinterpretation of ‘one-size-fits-all’ disclosure formats. Such issues can only be properly evaluated on the basis of a sound understanding of what the different rules say and how they interact with each other. See here for KPMG’s EU Tax Centre’s report and comparative overview on CBCR from an EU perspective, as an initial guide for carrying out such an evaluation.

KPMG insights into CBCR

General

  • KPMG’s response to the EU public consultation on further corporate transparency (search for KPMG in the third column: “Name of your organisation”)
  • KPMG Institutes: BEPS – tax transparency website
  • KPMG’s BEPS Action 13 country implementation summary

Public CBCR

Non-public CBCR 


Official documentation and resources

General

  • EU Commission website on company reporting

Non-public CBCR
  • EU Council Directive 2016/881 (amending Directive 2011/16/EU) as regards mandatory exchange of information in the field of taxation
  • The OECD maintains an up to date list of signatories on Action 13 BEPS


Public CBCR

  • EU Commission webpage on Public Country-by-Country Reporting / Corporate tax transparency
  • EU Commission proposal for amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches
     

CBCR Q&As

How KPMG can help and who to contact

Glossary of abbreviations

  • CE – Constituent Entity
  • CBCR – Country-by-country reporting
  • MNE Group – Multinational Entity (group)
  • UPE – Ultimate Parent Entity
  • OECD – Organisation for Economic Co-operation and Development
  • BEPS – the OECD’s Base Erosion and Profit Shifting project
  • PE – Permanent Establishment

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Country-by-Country Reporting Q&As

The latest information on the EU’s work and proposals on public and non-public CBCR.

 
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KPMG's CBCR Services

KPMG's CBCR Services

How KPMG can help and who to contact.

Key contact

E-News

KPMG's EU Tax Centre compiles this regular update of EU tax developments

 
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Euro Tax Flash

KPMG’s EU Tax Centre publishes a news bulletin that analyses CJEU...

 
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The KPMG Guide to CCCTB

Our Guide to CCCTB addresses the political background and the EU decision making process.

 
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EU Country Profiles

KPMG's European Tax Centre publishes a yearly profile on tax systems.

 
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