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New CbC Reporting Guidance Included In OECD's BEPS Update

Tuesday, February 13, 2018

The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) reporting (BEPS Action 13).

The Inclusive Framework also approved updates to the results for preferential regime reviews conducted by the Forum on Harmful Tax Practices (FHTP) in connection with BEPS Action 5.

The additional guidance on country-by-country reporting addresses two specific issues: the definition of total consolidated group revenue and whether non-compliance with the confidentiality, appropriate use, and consistency conditions constitutes systemic failure.

The OECD has also released a summary of the approaches adopted by member jurisdictions of the Inclusive Framework with respect to issues where the guidance allows for alternative approaches. These documents will continue to be updated with any further guidance that may be agreed.