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February 12, 2018
2018-0303

OECD releases country approaches to Country-by-Country Reporting Guidance and adds additional questions

The Organisation for Economic Co-operation and Development (OECD) released additional guidance on February 8, to give greater certainty to tax administrations and multinational enterprise (MNE) groups on the implementation and operation of Base Erosion and Profit Shifting (BEPS) Action 13 Country-by-Country (CbC) Reporting (CbCR). Accordingly, the existing guidance on the implementation of CbCR (the Guidance) has been updated to address two specific issues: (i) the definition of total consolidated group revenue, relevant to determine whether a filing obligation exists; and (ii) whether non-compliance with the confidentiality, appropriate use and consistency conditions constitutes a Systemic Failure, which could trigger an obligation for local filing of the CbC report.

A Global Tax Alert, attached below, provides additional details.

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Full text of Tax Alert 2018-0303

 

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