Base erosion and profit shifting

OECD releases further guidance for tax administrations and MNE Groups on Country-by-Country reporting


05/11/2019 - The OECD/G20 Inclusive Framework on BEPS has released additional interpretative guidance to give greater certainty to tax administrations and MNE Groups on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13).


The new guidance includes questions and answers on, amongst other topics, the treatment of dividends received, the operation of local filing, the use of rounded amounts in Table 1 of an MNE Group’s CbC report and the information that must be provided with respect to the sources of data used.


The complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far is presented in the document released today. This will continue to be updated with any further guidance that may be agreed.


In addition, a summary of common errors made by MNE Groups in preparing CbC reports has also been posted on the OECD website. The release of this summary will help MNE Groups in avoiding these errors and tax administrations in detecting them where they occur. This summary will be updated as further common errors, if any, are identified.



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), Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 1 45 25 98 92), or Matt Andrew, Senior Tax Advisor in the Tax Treaty, Transfer Pricing and Financial Transactions Division (+33 1 85 55 45 78).


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