Under the OECD/G20 Inclusive Framework on BEPS, jurisdictions have committed to implement minimum standards to improve transparency over the global operations of large multinational enterprises (MNEs). Today, the OECD releases the latest annual peer review results on the implementation of BEPS Action 13 on Country-by-Country Reporting (CbCR) covering 142 members of the Inclusive Framework on BEPS.
The BEPS Action 13 minimum standard on Country-by-Country Reporting requires tax administrations to collect and share detailed information on all large 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.
The ninth peer review of BEPS Action 13 assesses how jurisdictions are implementing the CbCR minimum standard as of April 2026 and underlines continued progress in strengthening tax transparency. Highlights include:
- Over 120 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.
- Where legislation is in place, the implementation of CbCR has been found largely consistent with the Action 13 minimum standard.
- More than 5100 bilateral relationships for the exchange of CbC reports are now in place.
The BEPS Action 13 peer review is an annual process, and the next peer review report will be released in the third quarter of 2027.
Inquiries should be directed to CTPA Communications Office of the OECD Centre for Tax Policy and Administration (CTPA).
