As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), the OECD invites public comments on the Review of the BEPS Action 13 minimum standard.


Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project (BEPS Action 13) established a three-tiered standardised approach to transfer pricing documentation, including a Country-by-Country Report (CbC report) that provides details of a multinational enterprise (MNE) group’s revenues, profit before tax, tax accrued and other information relevant to a high level risk assessment, for each tax jurisdiction in which the MNE group has a constituent entity. Country-by-Country reporting (CbC reporting) is one of four BEPS minimum standards which all members of the Inclusive Framework are committed to implementing.

The BEPS Action 13 report also included a requirement that a review of the CbC reporting ‎minimum standard be completed by the end of 2020 (the 2020 review).

Public consultation document

The Inclusive Framework released on the OECD website a public consultation document (also available in French) on matters where its members seek input from stakeholders in conducting this 2020 review. The public consultation document comprises three chapters: Chapter 1 contains general topics concerning the implementation and operation of BEPS Action 13; Chapter 2 contains topics concerning the scope of CbC reporting; and Chapter 3 contains topics concerning the content of a CbC report. Specific questions upon which comments are sought are set out in each chapter.

This public consultation document is based upon the mandate set out in the BEPS Action 13 report, and focuses on issues concerning the use of CbC reports by tax administrations for the purposes of a high level transfer pricing risk assessment, the assessment of other BEPS-related risks and economic and statistical analysis. On 31 January 2020 the Inclusive Framework also released a Statement on the Two-Pillar Approach to Address the Tax Challenges Arising From the Digitalisation of the Economy. Work on that approach may include consideration as to whether elements of the framework or principles underpinning CbC reporting may be used to support implementation and operation of Pillar 1 and/or Pillar 2, and input from stakeholders may be sought as part of that process. These matters are not considered.

The Inclusive Framework welcomes comments on all aspects of the BEPS Action 13 report, but specifically invites comments on the questions raised throughout the public consultation document. Interested parties are invited to send their comments no later than Friday, 6 March 2020, 18:00 (CET), by e-mail to [email protected] in Word format (in order to facilitate their distribution to government officials). All comments should be addressed to the International Co-operation and Tax Administration Division, Centre for Tax Policy and Administration.

Please note that all comments on this public consultation document will be made publicly available. Comments submitted in the name of a collective “grouping” or “coalition”, or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting. Speakers and other participants at the upcoming public consultation meeting in Paris will be selected from among those providing timely written comments on this consultation document.

Public consultation meeting

The public consultation meeting on the 2020 review of BEPS Action 13 will be held on 17 March 2020, at the OECD Conference Centre in Paris. The objective is to provide external stakeholders an opportunity to provide input on the ongoing work. Information on the public consultation meeting is available on the OECD website.

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