The OECD published its 2026 compilation of peer review reports on Country-by-Country Reporting, assessing the implementation of the BEPS Action 13 Minimum Standard across 142 jurisdictions.
The OECD published the Compilation of 2026 Peer Review Reports for Country-by-Country Reporting on 19 October 2026, presenting findings on the implementation of Country-by-Country (CbC) reporting across 142 jurisdictions that submitted relevant legislation or information.
The ninth annual peer review covered three areas: domestic legal and administrative frameworks, exchange of information frameworks, and the confidentiality and appropriate use of CbC reports.
Country-by-Country Reporting Requirements
Under the BEPS Action 13 Minimum Standard, jurisdictions require the largest multinational enterprise (MNE) groups to report the global allocation of their income, taxes and other indicators of economic activity.
CbC reports provide tax authorities with information about MNE groups’ operations across jurisdictions, helping them assess transfer pricing and other base erosion and profit shifting (BEPS) risks.
Since 2018, the OECD has conducted annual peer reviews to evaluate how jurisdictions have implemented the minimum standard.
Background to the BEPS Framework
The OECD and G20 launched the BEPS Action Plan in September 2013 to address tax avoidance by multinational enterprises and strengthen international tax rules. The plan set out 15 actions to improve the consistency of domestic tax rules, reinforce substance requirements and enhance transparency and certainty.
The resulting BEPS package was delivered to G20 Leaders in November 2015. The OECD/G20 Inclusive Framework on BEPS was subsequently established to support the consistent implementation of the recommendations and monitor progress through peer reviews. It brings participating countries and jurisdictions together on an equal footing.
Developments in international tax reform
The OECD/G20 Inclusive Framework has also advanced work on the Two-Pillar Solution to address tax challenges arising from the digitalisation of the economy. In October 2021, more than 135 members agreed to a political statement on the reform of international tax rules.
The work includes Pillar One measures on reallocating taxing rights and simplifying transfer pricing for certain baseline distribution activities through Amount B. Pillar Two includes the Subject-to-Tax Rule, which allows jurisdictions to impose a minimum rate on certain cross-border intra-group payments, and the GloBE Rules, which establish a 15% global minimum effective tax rate framework.
As of the beginning of 2025, more than 55 jurisdictions had implemented the Pillar Two GloBE Rules.
The Inclusive Framework reiterated the importance of certainty and stability in the international tax system at its April 2025 meeting.
The 2026 compilation was approved by the Inclusive Framework on BEPS on 9 October 2026 and prepared for publication by the OECD Secretariat.
