BEPS Action 13: 31 Countries Set To Exchange CbC Reports

31 countries have now signed a multilateral competent authority agreement (MCAA) enabling the automatic exchange of country-by-country reports (CbC reports) and addressing BEPS action 13.

31 countries have now signed a MCAA enabling the automatic exchange of CbC reports from each reporting entity between the competent authorities.

The agreement handles the exchange of CbC reports as stated in BEPS action plan 13. This action plan has amended Chapter V of the transfer pricing guidelines of the OECD. The guidelines are soft law and as such, OECD member countries are encouraged to follow these guidelines in their domestic transfer pricing practices.

CbC reporting is also part of the EU anti-tax avoidance package, which was proposed by the European Commission on 27 January 2016 and is tabled for political agreement by ECOFIN on 25 May 2016.

CbC reporting only applies for MNE Groups with a total consolidated income greater than €750,000,000. A CbC report is only required to be exchanged if both competent authorities have the MCAA in effect and their respective jurisdictions have legislation in effect that requires the filing of CbC reports with respect to the fiscal year to which the CbC report relates.

Countries that have currently implemented CbC reporting are...