2020 Review of Country-by-Country Reporting (BEPS Action 13 Minimum Standard)

As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), the OECD invites public comments on the Review of the BEPS Action 13 Minimum Standard.

Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project (BEPS Action 13) established a three-tiered standardised approach to transfer pricing documentation, including a Country-by-Country Report (CbC report) that provides details of an MNE group’s revenues, profit before tax, tax accrued and other information relevant to a high level risk assessment, for each tax jurisdiction in which the MNE group has a constituent entity. Country-by-Country reporting (CbC reporting) is one of four BEPS minimum standards which all members of the Inclusive Framework are committed to implementing.

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

The Inclusive Framework welcomes comments on all aspects of the BEPS Action 13 report, but specifically invites comments on the questions raised throughout the public consultation document. Interested parties are invited to send their comments no later than Friday, 6 March 2020, 18:00 (CET), by e-mail to taxpublicconsultation@oecd.org in Word format (in order to facilitate their distribution to government officials). All comments should be addressed to the International Co-operation and Tax Administration Division, Centre for Tax Policy and Administration.

The public consultation meeting on the 2020 review of BEPS Action 13 will be held virtually on 12-13 May 2020. The objective is to provide external stakeholders an opportunity to provide input on the ongoing work.

Please note that all comments on this public consultation document will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting. Speakers and other participants at the upcoming public consultation meeting in Paris will be selected from among those providing timely written comments on this consultation document.

Published 9 March 2020

The OECD is grateful to the commentators for their input and now publishes the public comments received.

• Download comments (Zip file, 18mb - Please open from a computer)

Update 12/03/2020: Comments have been added/replaced in their respective folders within the ZIP file. Please consult the "Read me" file for a description of all updates.

Enquiries should be addressed to taxpublicconsultation@oecd.org.