The OECD's Inclusive Framework on BEPS has released two sets of guidance to give greater certainty to tax administrations and MNE Groups alike on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13).
Existing guidance on the implementation of CbC Reporting has been updated and now addresses the following issues: 1) the definition of revenues; 2) the treatment of MNE groups with a short accounting period; and 3) the treatment of the amount of income tax accrued and income tax paid. The complete set of interpretative guidance related to CbC Reporting issued so far is presented in the document released today. This will continue to be updated with any further guidance that may be agreed.
Guidance has also been released on the appropriate use of the information contained in CbC Reports. This includes 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 administrations to ensure the appropriate use of CbCR information.
Bron: OECD
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