Base erosion and profit shifting

Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13


Guidance on the Implementation of Country-by-Country Reporting (BEPS Action 13)

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Update: 5 December 2016



The BEPS Action 13 report (Transfer Pricing Documentation and Country-by-Country Reporting) provides a template for multinational enterprises (MNEs) to report annually and for each tax jurisdiction in which they do business the information set out therein. This report is called the Country-by-Country (CbC) Report.


To facilitate the implementation of the CbC reporting standard, the BEPS Action 13 report includes a CbC Reporting Implementation Package which consists of (i) model legislation which could be used by countries to require the ultimate parent entity of an MNE group to file the CbC report in its jurisdiction of residence including backup filing requirements and (ii) three model Competent Authority Agreements that could be used to facilitate implementation of the exchange of CbC reports, respectively based on the:

  1. Multilateral Convention on Administrative Assistance in Tax Matters;
  2. Bilateral tax conventions; and
  3. Tax Information Exchange Agreements (TIEAs).


As jurisdictions have moved into the implementation stage, some questions of interpretation have arisen. In the interests of consistent implementation and certainty for both tax administrations and taxpayers, the OECD has issued this guidance to address the following five key questions.

  • Transitional filing options for MNEs that voluntarily file in the Parent jurisdiction;
  • CbC reporting notification requirements for MNE Groups during transitional phase (added Dec '16);
  • Guidance on the application of CbC reporting to investment funds;
  • Guidance on the application of CbC reporting to partnerships; and
  • The impact of exchange rate fluctuations on the agreed EUR 750 million filing threshold for MNE groups.



The Inclusive Framework on BEPS has released information on the domestic legal frameworks for CbC reporting around the world. This information provides a high level snapshot for tax administrations and MNE Groups as to the first reporting periods, availability of surrogate filing including in the parent jurisdiction, and local filing.


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