The Organisation for Economic Cooperation and Development (OECD) released on March 23, 2016 a standardized electronic format and a related user guide for the exchange of country-by-country (CbC) reports between jurisdictions.
The standardized electronic format is intended to allow for the swift and efficient implementation of the base erosion and profit shifting (BEPS) measures. The exchange of CbC reports-to be electronically transmitted between competent authorities—will assist tax administrations in obtaining a complete understanding of the way in which multinational enterprises structure their operations, by annually providing information on the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the taxpayer group. It will also cover information about which entities do business in a particular jurisdiction and the business activities each entity engages in.
The information to be included in the CbC report will be collected by the country of residence of the “reporting entity” for the taxpayer group, and will then be exchanged under the relevant international exchange of information agreement, in the format of the “CbC XML Schema.”
First exchanges of CbC reports will start in 2018, with information on the year 2016.