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On 13 September 2018, the OECD released additional guidance on the implementation of country-by-country reporting (CBCR) developed under Action 13 of the OECD BEPS action plan.

The new guidance provides additional clarifications with respect to a number of areas, including the treatment of dividends, the use of shortened numbers in Table 1, the treatment of major shareholdings and the treatment of mergers and acquisitions.  In some cases, MNE Groups will have filed CBCRs inconsistently with the additional guidance and will have to determine whether to amend CBCRs for prior and future reporting periods.

Further details regarding the the main changes are outlined below:

Treatment of dividends

Use of shortened amounts in Table 1