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May 29, 2018

OECD: ‘strong progress’ in country-by-country reporting across the globe

Practically all countries that serve as headquarters to large multinational enterprises (MNEs) have introduced new country-by-country reporting obligations, an OECD progress report has found.

Country-by-country exchanges are slated to begin in June 2018, and will see tax administrations worldwide collect and share detailed information on all large MNEs doing business in their country.

It forms one of the four Base Erosion and Profit Shifting (BEPS) minimum standards – each of which is subject to peer review to ensure effective and consistent implementation.

Information collected includes the amount of revenue reported, profit before income tax, and income tax paid and accrued, as well as the stated capital, accumulated earnings, number of employees and tangible assets, broken down by jurisdiction.

Before this, the OECD conducted a peer review focussing on the domestic legal and administrative framework.

 The review looked at 95 jurisdictions. Of these:

  • 60 had what was described as a comprehensive domestic legal and administrative framework in place, while a few had final legislation awaiting official publication as of 12 January 2018. 28 jurisdictions received on or more recommendations for improvement on specific areas of their framework, while 33 received a general recommendation to put in place of finalise their domestic legal and administrative framework was issued.
  • 58 jurisdictions had multilateral or bilateral competent authority agreements in place, effective for taxable periods starting on or after 1 January 2016, or on or after 1 January 2017.
  • 39 jurisdictions provided detailed information relating to appropriate use, enabling the Country-by-Country Reporting Group to reach specific assurance that measures are in place to ensure the appropriate use of Country-by-Country reports.

The second peer review into Country-by-Country reporting will focus on the exchange of information framework and appropriate use, and be published next year.

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