On 3 September 2019 the OECD has now issued the report on the stage two peer reviews looking at the implementation of CbC reporting requirements. A total of 116 jurisdictions are covered by the report.

Action 13 of the OECD action plan on base erosion and profit shifting (BEPS) included a recommendation that countries should introduce a requirement for country by country (CbC) reporting. Under the minimum standard countries are committed to increase tax transparency by requesting CbC reports from the largest multinational groups. The CbC reports set out details of the worldwide allocation of the income of the group on a country by country basis with details of taxes, assets, employees and other economic indicators. The reports can be exchange between countries and used to improve tax risk assessment.

A peer review process is taking place in relation to the implementation of the minimum standard by each country that has committed to the process. The peer reviews on Action 13 are being conducted in stages with annual reviews in 2017, 2018 and 2019, reflecting the phased implementation of the CbC reporting requirement.

The peer reviews look at the three key areas to be reviewed which are the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports.

The latest report notes that a domestic legal and administrative framework has been put into place in more than 80 jurisdictions in relation to CbC reporting. The report recommends to 41 jurisdictions that they should put into place or finalise their legal and administrative framework for CbC reporting.

The report notes that 67 jurisdictions have put into place arrangements relating to bilateral or multilateral competent authority agreements in relation to the exchange of country by country reports for 2016 and 2017.

A total of 73 jurisdictions have been assessed by the Global Forum in relation to confidentiality and data safeguarding under the standard on automatic exchange of information (AEOI) and a further twelve jurisdictions have been given an action plan by the Global Forum as a result of the review. The report also notes that 58 jurisdictions have provided detailed information to allow the CbC reporting group to be satisfied that measures have been put in place to ensure the appropriate use of the information in CbC reports.