The OECD on 5 December issued additional guidance on the implementation of the country-by-country reporting requirement introduced in the BEPS Action 13 Final Report. This guidance updates and expands the additional guidance issued on 29 June 2016.
In an effort to support consistent implementation of CbC reporting, the OECD added guidance covering CbC reporting notification requirements for MNE groups during the transitional implementation phase. It also provides the expanded list of countries that have indicated they will allow parent surrogate filing (that is, voluntary filing in parent jurisdiction), including Hong Kong, Liechtenstein, Nigeria, and Russia, along with Japan, Switzerland, and the United States, which had previously declared their intention to allow voluntary filing.
The OECD’s additional guidance covers:
- Transitional filing options for MNEs to address differences in effective dates (updated)
- CbC reporting notification requirements for MNE groups during the transitional phase (new)
- The application of CbC reporting to investment funds (unchanged)
- The application of CbC reporting to partnerships (unchanged)
- The impact of currency fluctuations on the agreed EUR 750 million filing threshold (unchanged)
Source & more info: Deloitte