The OECD is consulting on aspects of country-by-country (CbC) reporting, to inform the review it is required to deliver by the end of 2020. The document covers three broad areas:
general implementation and operation of BEPS Action 13 (transfer pricing documentation);
the scope of CbC reporting; and
the content of a CbC report.
One of the key issues raised is whether the current annual revenue threshold of €750m should be reduced to bring more groups within scope. The consultation document notes that multinational groups exceeding this threshold control approximately 90% of global corporate revenues and any further increase in coverage would be small. The document also questions whether it may be preferable for tax authorities to have the time and tools to consider fully CbC reports from existing in-scope groups first, before receiving more.
For groups already within scope, an important question relates to whether consolidation by country may be required, rather than aggregation. For many groups, this may lead to considerable additional work.
Comments should be sent by 6 March 2020. See bit.ly/2Hibvit.
The OECD is consulting on aspects of country-by-country (CbC) reporting, to inform the review it is required to deliver by the end of 2020. The document covers three broad areas:
general implementation and operation of BEPS Action 13 (transfer pricing documentation);
the scope of CbC reporting; and
the content of a CbC report.
One of the key issues raised is whether the current annual revenue threshold of €750m should be reduced to bring more groups within scope. The consultation document notes that multinational groups exceeding this threshold control approximately 90% of global corporate revenues and any further increase in coverage would be small. The document also questions whether it may be preferable for tax authorities to have the time and tools to consider fully CbC reports from existing in-scope groups first, before receiving more.
For groups already within scope, an important question relates to whether consolidation by country may be required, rather than aggregation. For many groups, this may lead to considerable additional work.
Comments should be sent by 6 March 2020. See bit.ly/2Hibvit.
