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The OECD recently initiated a review under BEPS Action 13 of country-by-country reporting (CbCR) based on a mandate in the final 2015 BEPS report that an assessment occur in 2020. CbCR is a minimum standard for participating BEPS Inclusive Framework (IF) members, pursuant to which all large multinational enterprises (MNEs) are required to prepare a CbC report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which it operates. This CbC report is shared with tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments. The first CbCR reporting requirement took effect in 2016 in some jurisdictions, so in-scope multinationals and tax authorities have only had a few years of experience with this complex reporting framework.

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