Base erosion and profit shifting

OECD/G20 Inclusive Framework on BEPS shows progress in implementing tax transparency through Action 13 Country-by-Country reporting


24/09/2020 - The OECD has released the outcomes of the third phase of peer reviews of the BEPS Action 13 Country-by-Country (CbC) reporting initiative, demonstrating strong progress in continuing efforts to improve the taxation of multinational enterprises (MNEs) worldwide.


CbC reporting, one of the four minimum standards of the BEPS Project, 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. CbC reporting provides an unprecedented level of transparency to tax administrations worldwide. As a result, tax administrations, often for the first time, will have received detailed information on all large MNEs doing business in their country. As CbC Reporting is one of the four minimum standards of the BEPS Project, all members of the Inclusive Framework on BEPS have committed to implement it, and to have their compliance with the standard reviewed and monitored by their peers. This is to ensure a timely and consistent implementation across the world, which is key to the success of CbC reporting.


This third annual peer review considers implementation of the CbC reporting minimum standard by jurisdictions as of April 2020. Highlights include:

  • Coverage increased to 131 jurisdictions. The peer review includes a comprehensive examination of 131 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 these will be reviewed as soon as possible.

  • Practically all MNEs that are over the threshold for filing are now covered. Over 90 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. A large number of recommendations made in the first two peer review phases have now been addressed and these recommendations have been removed.

  • Over 2500 exchange relationships now in place. Exchanges of CbC reports began in June 2018 and more than 2500 bilateral relationships for CbC exchanges are now in place.


Related work

In addition, work progresses on the 2020 review of the CbC reporting minimum standard, to be completed this year. This will take into account feedback received from a public consultation, including a meeting held in May 2020 via Zoom with around 270 participants from business and non-business stakeholders.


Work continues to support the effective use of CbC reports by tax administrations. Building on the OECD Forum on Tax Administration (FTA) Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment, an automated Tax Risk Evaluation and Assessment Tool (TREAT) has been developed to help tax administrations use CbC reports identify key indicators of potential tax risk, including those described in the Handbook. CbC reports are also at the heart of several FTA projects, including the International Compliance Assurance Programme (ICAP) for a co-ordinated risk assessment of large MNEs, currently in a second pilot phase including 19 tax administrations, and the Comparative Risk Assessment (CoRA) initiative to improve tax administrations’ understanding of common international tax risks and identify areas of consistency and difference in how these are currently detected. Particular efforts are also underway to help developing countries benefit fully from Action 13.



Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 08 ), or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 1 45 24 98 92 ).


Related Documents