On 6 April 2017 the Inclusive Framework on BEPS released additional guidance on the implementation of country by country (CbC) reporting under BEPS Action 13. The guidance clarifies some issues surrounding the information to be included in the CbC report and application of the model legislation contained in the Action 13 report, to assist jurisdictions with the introduction of consistent domestic rules.
The issues addressed in the guidance are the definition of revenues; the accounting principles and standards for determining the existence of and membership in a group; the definition of total consolidated group revenue; the treatment of major shareholdings; and the definition of a related party for the purposes of completing the information required for Table 1 of the CbC report.
More than 100 countries are involved in the Inclusive Framework and in the development of the monitoring process for the four minimum standards and the review mechanisms for other parts of the BEPS package. The inclusive framework is also developing various toolkits to assist developing countries in BEPS implementation. The inclusive framework allows these countries to provide input to the work on toolkits and to impact the remaining BEPS standard-setting work.
The guidance document will be updated for any further guidance that may subsequently be published.
