On 13 September 2018 the OECD’s Inclusive Framework released additional interpretative guidance in relation to Country-by-Country (CbC) reporting under Action 13 of the OECD/G20 report on base erosion and profit shifting (BEPS). More than 100 countries are involved in the Inclusive Framework which is implementing the monitoring process for the four minimum standards under BEPS as well as the review mechanisms for other parts of the BEPS package.  The Inclusive Framework is also involved in developing various toolkits to assist developing countries in BEPS implementation.

The interpretative guidance on CbC reporting 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 latest updates to the guidance deal with issues related to the treatment of dividends received and questions arising in relation to the number of employees to be reported in certain cases where a multinational enterprise uses proportional consolidation in preparing its consolidated financial statements. The updated guidance also clarifies that in completing Table 1 of a CbC report the whole amounts should be shown and they should not be shortened to the nearest thousand.

In Part IV.1.2 of the guidance a table has been inserted summarising the existing interpretative guidance on the approach to be applied in cases of mergers, demergers and acquisitions.

The Inclusive Framework has released the whole of its guidance as updated for the latest issues and this will continue to be updated with any further guidance issued.