The OECD has released the outcomes of the second phase of peer reviews of the BEPS Action 13 Country-by-Country (CbC) reporting initiative.

The second annual peer review considers implementation of the CbC reporting minimum standard by jurisdictions as of April 2019. Highlights include:

  • Coverage increased to 116 jurisdictions. The peer review includes a comprehensive examination of 116 Inclusive Framework members. A small number of members were not included in this review either because they recently joined the Inclusive Framework or they faced capacity constraints, but they will be reviewed as soon as possible.
  • Practically all large MNEs now covered. Over 80 jurisdictions have already introduced legislation to impose a filing obligation on MNE groups, covering almost all MNE Groups with consolidated group revenue at or above the threshold of EUR 750 million. Remaining Inclusive Framework members are working towards finalising their domestic legal frameworks with the support of the OECD.
  • Implementation largely consistent with BEPS Action 13. Where legislation is in place, the implementation of CbC Reporting has been found largely consistent with the Action 13 minimum standard.
  • Jurisdictions acting on prior recommendations. 62 recommendations made in the first peer review have been addressed and these recommendations have been removed.
  • Over 2200 exchange relationships now in place. Exchanges of CbC reports began in June 2018 and more than 2200 bilateral relationships for CbC exchanges are now in place.

CbC reporting is one of the four minimum standards of the OECD/G20 Base erosionand profit shifting (BEPS) Project. The initiative requires tax administrations to collect and share detailed information on all large multinational enterprises (MNEs) doing business in their country. Information collected includes the amount of revenue reported, profit before income tax, and income tax paid and accrued, as well as the stated capital, accumulated earnings, number of employees and tangible assets, broken down by jurisdiction.

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