OECD releases further guidance on Country-by-Country reporting (BEPS Action 13)

CBCR and appropriate use of information

The OECD’s Inclusive Framework on BEPS has updated the existing guidance on the implementation of CbC Reporting that now addresses the following issues:

  • the definition of revenues;
  • the treatment of MNE groups with a short accounting period; and
  • the treatment of the amount of income tax accrued and income tax paid.

OECD has also realized a new guidance on the meaning of “appropriate use” of the information contained in CbC Reports, the consequences of non-compliance with the appropriate use condition and the approaches that may be used by tax administrations to ensure the appropriate use of CbCR information.