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.