On December 5, 2016 the Inclusive Framework on BEPS has released two new documents to support the global implementation of Country-by-Country (CbC) reporting (BEPS Action 13):

·   Key details of jurisdictions' domestic legal frameworks for CbC reporting; and

·   Additional interpretive guidance on the CbC reporting standard (An update of the “Guidance on the Implementation of Country-by-Country Reporting – BEPS Action 13”).

 

The purpose of the documents is to provide essential information and to provide certainty to tax administrations and MNE Groups alike on implementation of CbC reporting.

 

Key details of jurisdictions' domestic legal frameworks for CbC reporting

On December 5, 2016 the OECD released a webpage containing Country-Specific Information on Country-by-Country Reporting Implementation. The webpage provides a high level snapshot for tax administrations and MNE Groups. The details include the status of the legislation, first reporting periods, availability of surrogate filing and voluntary filing, and whether local filing can be required. According to the OECD, the table on the webpage contains the information received from members so far and will be updated as Inclusive Framework members continue to finalize their CbC reporting frameworks.

 

The OECD furthermore states that coming months also Information will be published in as to the Qualifying Competent Authority Agreements (QCAA) being put in place to facilitate the international exchange of CbC reports between tax administrations.

 

Click here to be forwarded to the webpage “Country-Specific Information on Country-by-Country Reporting Implementation” as available on the website of the OECD.

 

Additional interpretive guidance on the CbC reporting standard

On December 5, 2016 the OECD released an update of the “Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13”, of which the initial version was released on June 29, 2016.

 

The additional guidance relates to the case where a notification to the tax administration may be required to identify the reporting entity within a MNE Group (as provided in Article 3 of the Model Legislation in the Action 13 Report). The guidance confirms that if such notifications are required, jurisdictions have flexibility as to the due date for such notifications. This may be particularly relevant during the transition period where jurisdictions are still completing their implementation of CbC reporting, as MNE Groups may not yet have the necessary information to submit their notifications. The guidance also confirms that jurisdictions may wish to consider other transitional relief for MNE Groups with respect to these notifications, which would also be consistent with the minimum standard.

 

Click on the language of your choice to be forwarded to the “Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13” as updated by the OECD on December 5, 2016, (English or French) The OECD has announced that the update in the German language will follow soon.

 


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