OECD releases electronic format for exchange of BEPS country-by-country tax reports

The OECD on Tuesday released a standardized electronic format for the exchange between tax administrations of country-by-country (CbC) reports about multinational corporations, implementing final agreements reached under the OECD/G20 base erosion profit shifting (BEPS) plan. The CbC XML Schema is accompanied by a related user guide.

Information to be included in the CbC report will be collected by the country of residence of the reporting entity for a multinational group and will then be exchanged under international exchange of information agreements, such as the OECD’s Multilateral Competent Authority Agreement on the Exchange of CbC Reports, in the format of the CbC XML Schema.

The plan is designed to provide tax administrations with more information about multinationals’ tax affairs to enable countries to combat corporate tax avoidance through transfer pricing.

Andrew Cousins, director of Duff & Phelps’ London transfer pricing practice, criticized aspects of the CbC XML Schema that require the provision of identification data relating to each and every group entity.

This requirement “is an additional compliance burden on multinational companies . . .  over and above the requirements seen in last year’s BEPS outcomes,” Cousins said.

Cousins added that”significant concerns remain over the potential for loss of confidential company data through electronic exchange of information between governments. He said that he would welcome additional guidance on measures taken to ensure data security throughout the reporting process.

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