REGULATION: OECD Reviewing Country-by-Country Reporting Rules.

As published on accountancydaily.co, Monday February 10, 2020.


The review will look at the BEPS Action 13 minimum standard, which established a three-tiered standardised approach to transfer pricing documentation, including CBCR requirements to provide details of a multinational group’s revenues, profit before tax, tax accrued and other information relevant to a high level risk assessment, for each tax jurisdiction in which the group has a constituent entity.

CBCR is one of four BEPS minimum standards which all members of the inclusive framework are committed to implementing.

The Action 13 report included a requirement that a review of the CBCR ‎minimum standard be completed by the end of 2020.

As part of that review there is a public consultation covering three issues: the implementation and operation of BEPS action 13; the scope of CBCR; and the content of a CBCR report. Specific questions upon which comments are set out in each chapter.

They include whether modifications to the content of CBCR reports should be made, to require the reporting of additional or different data; the appropriateness of the applicable revenue threshold; and the effectiveness of filing and dissemination mechanisms.

The consultation will focus on issues concerning the use of CBCR by tax administrations for the purposes of a high level transfer pricing risk assessment, the assessment of other BEPS-related risks and economic and statistical analysis.

In January the inclusive framework issued a statement on the proposed two pillar approach to addressing the tax challenges of the digital economy.

The OECD said work on that approach may include consideration as to whether elements of the framework or principles underpinning CBCR reporting may be used to support implementation and operation of Pillar 1 and/or Pillar 2. However, these matters do not form part of the current consultation.

The deadline for comment is 6 March. There is a public consultation meeting on the 2020 review of BEPS Action 13 on 17 March 2020, at the OECD Conference Centre in Paris.