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In brief: OECD Guidance on Country by Country reporting

The Organisation for Economic Cooperation and Development (OECD) released on 6 April 2017 additional guidance for tax administrations and multinational enterprises to use in implementing country-by-country (CbC) reporting pursuant to the base erosion and profit shifting (BEPS) Action 13 recommendations.

The Guidance clarifies several interpretation issues related to the data that is to be included in the CbC report as well as applying the model legislation contained in the BEPS Action 13 report, to assist jurisdictions with introducing consistent domestic rules.

The guidance addresses five specific issues:

  • The definition of revenues
  • The accounting principles/standards for determining the existence of and membership in a group
  • The definition of total consolidated group revenue
  • The treatment of major shareholdings
  • The definition of related party

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