As jurisdictions have moved into the implementation stage, some questions of interpretation have arisen. In the interests of consistent implementation and certainty for tax administrations and taxpayers, the Inclusive Framework on BEPS has issued guidance to address certain key questions. This guidance is periodically updated.

• English (Version: May 2024)
• French (Version: May 2024)
• German (Version: September 2018)
• Spanish (Version: December 2019)

Also available is a compilation of the approaches adopted by jurisdictions, in cases where guidance provides flexibility:

• English
  
• French
  
• Spanish

One of the conditions for receiving and using CbC Reports is that a jurisdiction must have in place the necessary framework and infrastructure to ensure the appropriate use of CbCR information. To assist jurisdictions in complying with this condition, the OECD has released guidance on the meaning of "appropriate use", the consequences of non-compliance with the appropriate use condition and approaches that may be used by tax authorities to ensure the appropriate use of CbCR information.

• English (September 2017)
• French (September 2017)
• German (September 2017)
• Spanish  (September 2017)

Tax administrations have encountered several concerns with the data in CbC reports filed to date, and descriptions of the most common of these have been compiled in a table that is available to view. MNEs within the scope of CbC reporting should review these descriptions and ensure that these errors are not repeated in CbC reports they are preparing. Where a tax administration identifies that a CbC report filed with it contains errors (including but not limited to those described in the table) it should require these errors to be corrected by the Reporting MNE.

• English

Published 27 September 2017

Download the report (PDF)

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Country-by-Country (CbC) Reporting is one of the four minimum standards under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project to which over 100 countries have committed, covering the tax residence jurisdictions of nearly all large MNE groups. Where CbC Reporting is implemented effectively, and in line with the conditions set out in the BEPS Action 13 Report, it will give tax authorities unprecedented access to information on the global allocation of an MNE group's revenue, profit, tax and other attributes for high-level transfer pricing risk assessment and the assessment of other BEPS-related risks.

This handbook is a practical guide to assist countries in implementing CbC Reporting into their domestic law, taking into account:

• key factors that countries should consider in introducing a domestic legal framework for the filing and use of CbC Reports;
• issues concerning the implementation and operation of an international framework for the exchange of CbC Reports;
• operational aspects of CbC Reporting, including mechanisms to identify entities required to file CbC Reports in a country, the handling of CbC Reports and the importance of effective sanctions for non-compliance; and
• practical issues including the importance of guidance to taxpayers and tax authority staff, engaging with stakeholders and providing training for staff who will deal with CbC Reports.

Web announcement

• 29/09/2017 - Leading tax administrations focused on effective delivery of the OECD/G20 BEPS outcomes, automatic exchange of information and tax certainty and collaborate on taxing users of the sharing economy

Published: 29 September 2017

Download the report (PDF)

• English
• French
• Spanish

Country-by-Country (CbC) Reporting is one of the four minimum standards under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project to which over 100 countries have committed, covering the tax residence jurisdictions of nearly all large MNE groups. Where CbC Reporting is implemented effectively, and in line with the conditions set out in the BEPS Action 13 Report, it will give tax authorities unprecedented access to information on the global allocation of an MNE group's revenue, profit, tax and other attributes for high level transfer pricing risk assessment and the assessment of other BEPS-related risks.

This handbook supports countries in the effective use of CbC Reports by incorporating them into a tax authority's risk assessment process, including:

• a description of the role of tax risk assessment in tax administration, the core characteristics of an effective risk assessment system, and examples of the approaches used in different countries;
• an outline of the information contained in CbC Reports, and the potential advantages CbC Reports have over data from other sources;
• consideration of the ways in which CbC Reports can be incorporated into a tax authority's risk assessment framework and a description of some of the main potential tax risk indicators that may be identified using CbC Reports;
• a description of some of the challenges that may be faced by a tax authority in using CbC Reports for tax risk assessment and how some of these may be dealt with;
• an outline of some of the other sources of data that may be used by a tax authority alongside CbC Reports; and
• an overview of how the results of a tax risk assessment using CbC Reports may be used and the next steps that should be taken.

Web announcement

• 29/09/2017 - Leading tax administrations focused on effective delivery of the OECD/G20 BEPS outcomes, automatic exchange of information and tax certainty and collaborate on taxing users of the sharing economy