Country-by-Country Reporting – Compilation of 2022 Peer Review Reports
Inclusive Framework on BEPS: Action 13
Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity. This unprecedented information on MNE Groups’ operations across the world has boosted tax authorities’ risk-assessment capabilities. The Action 13 Minimum Standard was translated into specific terms of reference and a methodology for the peer review process. The peer review of the Action 13 Minimum Standard has completed four annual reviews in 2018, 2019, 2020 and 2021. These cover the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of Country-by-Country (CbC) reports. This fifth annual peer review report reflects the outcome of the fifth review which considered all aspects of implementation. It contains the review of 134 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.
Also available in: French
Executive summary
A key component of the transparency pillar of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is the obligation for all large multinational enterprise groups (MNE Groups) with consolidated group revenue above an agreed threshold to file a Country-by-Country (CbC) report. The Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report provides a template for these MNE Groups to report annually, and for each tax jurisdiction in which they do business, the amount of revenue, profit before income tax and income tax paid and accrued, as well as the number of employees, stated capital, retained earnings and tangible assets. MNE Groups should also identify each entity within the group doing business in a particular jurisdiction and provide an indication of the business activities each entity is engaged in. As a result of BEPS Action 13, tax administrations around the world are receiving information on large foreign-headed MNE Groups which was not previously available, enabling them to better understand the structure of a group’s business and enhancing their risk assessment capacity.
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