UK and International Tax news

OECD Issues Consultation Document On The Review Of CbC Reporting

Friday 7th February 2020

As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS, the OECD has invited public comments on the Review of the BEPS Action 13 minimum standard.

Action 13 established a three-tiered standardised approach to transfer pricing documentation, including:

– a master file with high level information regarding an MNE’s global business operations and transfer pricing policies,

– a local file with detailed transactional transfer pricing documentation specific to each jurisdiction, and

– a CbC Report that provides annual details of revenues, profit before tax, tax paid and accrued and other information relevant to a high level risk assessment, for each tax jurisdiction in which the MNE group has a constituent entity.

The Action 13 report also included a requirement that a review of the CbC reporting ‎minimum standard be completed by the end of 2020.

The OECD has now issued a consultation document on matters where its members seek input from stakeholders in conducting their 2020 review. The document focuses on issues concerning the use of CbC reports by tax administrations for the purposes of a high level transfer pricing risk assessment and the assessment of other BEPS-related risks and economic and statistical analysis.  In particular, it raises questions on the implementation and operation of BEPS Action 13, the scope of CbC reporting and the content of a CbC report.

Interested parties have been invited to submit their comments by 6 March 2020.


If you would like further detail on the above, please contact Keith Rushen on 0207 486 2378.


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