OECD Releases Further Guidance on Country-by-country Reporting

April 2017

Multinationals will have an easier time understanding the requirements of country-by-country reporting due to the release of the Inclusive Framework on base erosion and profit shifting (BEPS), which contains further guidance on the subject.

The additional guidance aims to clarify several interpretation issues related to the data included in the country-by-country (CbC) report, as well as applications for the model legislation contained in the Action 13 report, which certainly will be welcome as jurisdictions roll out domestic rules on CbC reporting.

Many multinationals see CbC reporting as a burdensome, costly and time-consuming requirement, and several aspects have left room for interpretation by both tax authorities and multinationals. With the additional guidance, the Organisation for Economic Co-operation and Development (OECD) hopes to make life easier by clarifying the requirements.

Five specific issues are addressed in this guidance:

  1. The definition of ‘revenue’
  2. The accounting principles/standards for determining the existence of and membership in a group
  3. The definition of ‘total consolidated group revenue’
  4. The treatment of major shareholdings, and
  5. The definition of ‘related party’ for the purpose of completing Table 1 of the CbC report.


The update will give certainty to tax administrations and multinational groups alike on implementation of CbC reporting, the OECD said.

The guidance comes as almost 50 delegates from 14 countries gathered in Georgia for the second regional meeting on the Inclusive Framework on BEPS in the Eastern Europe and Central Asia regions. The participants discussed BEPS implementation and recent developments in transfer pricing, including CbC reporting. The meeting is a part of a series of regional events which allow participants to provide their input to the Inclusive Framework on BEPS.

The OECD said that additional guidance on CbC reporting will be published as necessary to ensure swift implementation of CbC reporting.

The above article was first published on www.internationaltaxreview.com on 20 April 2017 and has been republished with the approval of the Publisher.