Additional guidance on the implementation of country-by-country reporting by large multinational groups was released today by countries known as the “Inclusive Framework on BEPS,” the OECD has announced.
This guidance is designed for both multinational group taxpayers that must comply with country-by-country reporting rules and for tax administrations.
The additional guidance addresses how to treat an entity owned and/or operated by two or more unrelated multinational groups and whether aggregated data or consolidated data for each jurisdiction is to be reported in Table 1 of the country-by-country report prepared by the multinational.
The guidance has been incorporated into a document which sets out all of the country-by-country reporting guidance issued to date.
The Inclusive Framework on BEPS is comprised of 102 countries that have pledged to adopt “minimum standards” for preventing tax avoidance by multinational enterprises and for improving cross-border tax dispute resolution.
These minimum standards were set by G20 and OECD nations in the 2015 base erosion profit shifting (BEPS) project. One minimum standard is the implementation of country-by-country reporting by multinationals.
In exchange for this agreement, the countries participate in international tax standard setting work as a group to implement the BEPS project.