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OECD releases further guidance on country-by-country reporting

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The OECD has issued two further updates to its guidance on the implementation and operation of country-by-country reporting (BEPS Action 13). The existing guidance is updated to address:

·        the definition of revenues;

·        treatment of groups with a short accounting period; and

·        treatment of income tax accrued and income tax paid.

In addition, new guidance covers the ‘appropriate use’ by tax administrations of information contained in country-by-country reports. This instructs national tax authorities not to use the information for anything other than assessing high-level transfer pricing, risks related to base erosion and profit shifting, or economic and statistical analysis. Where a tax authority fails to comply with these conditions, it will automatically have to retract its tax assessment if challenged by the company concerned.


Issue: 1368
Categories: News