Country-by-Country Reporting – Compilation of 2022 Peer Review Reports
Inclusive Framework on BEPS: Action 13
Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency
by requesting the largest multinational enterprise groups (MNE Groups) to provide
the global allocation of their income, taxes and other indicators of the location
of economic activity. This unprecedented information on MNE Groups’ operations across
the world has boosted tax authorities’ risk-assessment capabilities. The Action 13
Minimum Standard was translated into specific terms of reference and a methodology
for the peer review process. The peer review of the Action 13 Minimum Standard has
completed four annual reviews in 2018, 2019, 2020 and 2021. These cover the three
key areas under review: the domestic legal and administrative framework, the exchange
of information framework, and the confidentiality and appropriate use of Country-by-Country
(CbC) reports. This fifth annual peer review report reflects the outcome of the fifth
review which considered all aspects of implementation. It contains the review of 134
jurisdictions which provided legislation or information pertaining to the implementation
of CbC Reporting.
Available from October 04, 2022Also available in: French
Ce recueil inclut les versions en français des rapports d’examen des pays francophones suivants : la Belgique, le Bénin, le Cameroun, le Canada, le Congo, la Côte d’Ivoire, Djibouti, la France, le Gabon, Haïti, le Luxembourg, le Maroc, Maurice, Monaco, la République démocratique du Congo, le Sénégal, les Seychelles, la Suisse, le Togo et la Tunisie.
Over 100 jurisdictions have by now introduced legislation to impose a filing obligation on MNE groups, covering practically all MNE Groups with consolidated group revenue at or above the threshold of EUR 750 million. Remaining Inclusive Framework members are working towards finalising their domestic legal frameworks with the support of the OECD.
Where legislation is in place, the implementation of CbC Reporting has been found largely consistent with the Action 13 minimum standard.
A large number of recommendations made in the past four peer review phases have now been addressed and these recommendations have been removed.
More than 3000 bilateral relationships for the exchange of CbC reports are in place as of April 2022.
The Country-by-Country Reporting requirements form one of the four BEPS minimum standards. Each of these minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the Action 13 minimum standard on CbC reporting, and to participating in the peer review.