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OECD update on country-by-country reporting implementation

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The multilateral competent authority agreement (MCAA) for exchange of CbC reports under BEPS action 13 has now been signed by 57 jurisdictions, representing more than 700 automatic exchange relationships. The OECD has provided an update on progress made on agreements to ensure that relationships are in place to start automatic exchanges. The update covers domestic implementation of ultimate parent entity filing, surrogate filing and voluntary parent surrogate filing, and steps to address concerns about local filing obligations. Reporting will apply to reporting fiscal years of multinational groups commencing on or after 1 January 2016, with the first automatic exchanges to take place no later than June 2018.

  • Of the 57 signatories to the CbC MCAA, over 30 have notified the OECD of the other signatories with which they intend to have agreements in place. Others continue to work towards bilateral competent authority agreements for exchange under double tax conventions or tax information exchange agreements.
  • EU member states will exchange automatically under the Development Assistance Committee (DAC).
  • Around 45 jurisdictions have implemented an obligation for the filing of CbC reports by resident ultimate parent entities (UPEs).
  • Ten countries have informed the OECD that they will permit voluntary parent surrogate filing by the resident UPE of a group, while around 45 countries will permit surrogate filing by constituent entities that are not the UPE of their group.
  • ‘Local filing’ by entities that are not the UPE of their group can only be applied in specific circumstances. The OECD is therefore working with jurisdictions to support them in putting in place filing obligations on resident UPEs and qualifying competent authority agreements with other jurisdictions, to avoid local filing wherever possible.
  • Certain jurisdictions which require filing by resident UPEs before 31 December 2017, and also have the capacity to impose a local filing obligation on resident entities that are not UPEs, are keen to ensure that both do not apply, with Brazil and China having issued specific guidelines.


Issue: 1353
Categories: News