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September 14, 2018
2018-1821

OECD releases additional guidance on Country-by-Country Reporting and updated exchange relationships

The Organisation for Economic Co-operation and Development (OECD) released additional guidance on September 13, 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 the following issues: (i) the treatment of dividends for purposes of "Profit (loss) before Income Tax," "Income Tax accrued (current year)," and "Income Tax paid (on cash basis);" (ii) the use of shortened amounts in Table 1 of CbC reports; and (iii) the number of employees to be reported where the financial data of a Constituent Entity is reported on a pro-rata basis. The updated Guidance also includes a summary table of the existing interpretative guidance on cases of mergers, demergers and acquisitions.

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

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