BEPS: Further Guidance on Country-by-Country Reporting and Peer Review Reports on the Exchange of Information on Tax Rulings

The Inclusive Framework on Base Erosion and Profit Shifting (BEPS) has released additional interpretative guidance to give greater certainty to tax administrations and multinational enterprise groups on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13). The new guidance makes clear that, under the BEPS Action 13 minimum standard, the automatic exchange of CbC reports filed under local filing rules is not intended.

In addition, a summary of CbC reporting notification requirements in Inclusive Framework member jurisdictions has been posted on the OECD website. The release of this summary will help MNE Groups in complying with notification requirements in different jurisdictions where they have constituent entities.

The Inclusive Framework on BEPS has also released the 2018 Peer Review Reports on the Exchange of Information on Tax Rulings. The reports assessed 112 jurisdictions’ progress in spontaneously exchanging information on tax rulings, in accordance with BEPS Action 5.