Countries launch review of country-by-country reporting framework for multinational groups

An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.

The country-by-country reporting scheme, developed by OECD and G20 countries in 2015, requires tax administrations to collect and share with other tax administrations information about MNE groups that operate in their countries, including MNE group revenue, profit before tax, and tax accrued.

The goal is to give tax offices information needed to assess whether there is a risk that an MNE group is avoiding tax through inappropriate transfer pricing or other means.

All members of the Inclusive Framework have agreed to implement the country-by-country reporting scheme for multinationals. About 90 countries have put the rules in place so far.

It was agreed to also in 2015 that the country-by-country reporting scheme would be reviewed in 2020, prompting the Inclusive Framework consultation document and request for stakeholder input.

Comments are sought by March 6. Although comments on all aspects of the scheme are welcome, the consultation document also lists specific questions upon which comments are sought.

The specific questions include whether the revenue threshold triggering the reporting requirement should be changed, whether reporting should be extended to single enterprises with foreign permanent establishments, and whether changes or additions should be made to the required disclosures.