Action 13 Country-by-Country Reporting
Minimum StandardUnder BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which it operates. This CbC report is shared with tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments.

Action overview
Key facts
110+ jurisdictions
have introduced CbC reporting filing obligation
3300+
bilateral relationships exist for the exchange of CbC reports
136 jurisdictions
are covered in the sixth annual peer review process
Action specific content
Guidance and handbooks
The Inclusive Framework has released a number of guidance and handbooks to assist and give greater certainty to tax administrations and MNE Groups alike on the implementation and operation of Country-by-Country (CbC) Reporting under BEPS Action 13.
Guidance on the implementation of CbC Reporting
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 Inclusive Framework has issued guidance to address certain key questions. This guidance is periodically updated. Also available is a compilation of the approaches adopted by jurisdictions, in cases where guidance provides flexibility.
Common errors made by MNEs in preparing CbC Reports
Tax administrations have encountered a number of concerns with the data in CbC reports filed to date, and descriptions of the most common of these have been compiled in a table that is available to view. MNEs within the scope of CbC reporting should review these descriptions and ensure that these errors are not repeated in CbC reports they are preparing. Where a tax administration identifies that a CbC report filed with it contains errors (including but not limited to those described in the table) it should require these errors to be corrected by the Reporting MNE.
Guidance on the appropriate use of information contained in CbC Reports
One of the conditions for receiving and using CbC Reports is that a jurisdiction must have in place the necessary framework and infrastructure to ensure the appropriate use of CbCR information. To assist jurisdictions in complying with this condition, the OECD has released guidance on the meaning of "appropriate use", the consequences of non-compliance with the appropriate use condition and approaches that may be used by tax authorities to ensure the appropriate use of CbCR information.
Handbook on Effective Implementation
Country-by-Country Reporting: Handbook on Effective Implementation is a practical guide to assist countries in implementing CbC Reporting in line with the Action 13 minimum standard. This includes chapters on the filing and use of CbC Reports, the exchange of CbC Reports, operational aspects of CbC Reporting and guidance, stakeholder engagement and training.
Handbook on Effective Tax Risk Assessment
Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment supports countries in the effective use of CbC Reports by incorporating them into a tax authority's risk assessment process. The handbook explores the advantages CbC Reports offer over other sources of data for risk assessment, how CbC Reports may be used by a tax administration to risk assess MNE groups including some of the tax risk indicators that may be identified, a number of challenges tax administrations may face in using CbC Reports and how these may be addressed, and other data sources that should be used alongside CbC Reports, where available.
All reports