OECD: Updated Guidance on the Implementation of Country-by-Country Reporting

Published on May 12, 2017

According to BEPS Action 13 (”Action 13: 2015 Final Report - Transfer Pricing Documentation and Country-by-Country Reporting”) countries should adopt a standardized approach to transfer pricing documentation that includes the three-tiered structure that encompasses a master file, a local file and a Country-by-Country Report (”CbC Reporting”). In order to continue the consistent and swift implementation of the CbC Reporting, the OECD will endeavor to provide common public guidance.

The updated ”Guidance on the Implementation of Country-by-Country Reporting” addresses several issues where questions of interpretation have arisen. The guidance of April 2017 covers the following issues:

Issues relating to the definition of items reported in the template for the CbC report, such as:
- revenue
- related party

Application of CbC reporting to investment funds
Application of CbC reporting to partnerships
Accounting principles/standards for determining the existence of and membership of a group
Treatment of major shareholdings
Impact of currency fluctuations on the agreed EUR 750 million filing threshold
Definition of total consolidated group revenue
Transitional filing options for MNEs (”parent surrogate filing”)
CbC Reporting notification requirements for MNE Groups during transitional phase

For further information see:
http://www.oecd.org/tax/beps/oecd-releases-further-guidance-for-tax-administrations-and-mne-groups-on-country-by-country-reporting-beps-action-13.htm

OECD releases further guidance for tax administrations and MNE Groups on Country-by-Country reporting (BEPS Action 13)