The OECD peer review report covers 142 jurisdictions that have submitted legislation or information on the implementation of CbC reporting.
The OECD has released the Compilation of 2025 Peer Review Reports on Country-by-Country Reporting on 23 September 2025, covering 142 jurisdictions that have submitted legislation or information on the implementation of CbC reporting.
Under the OECD/G20 Inclusive Framework on BEPS, jurisdictions have committed to implement minimum standards to improve transparency over the global operations of large multinational (MNE) groups.
The BEPS Action 13 minimum standard on Country-by-Country reporting requires tax administrations to collect and share detailed information on all large MNEs doing business in their country. Information collected includes the amount of revenue reported, profit before income tax, and income tax paid and accrued, as well as the stated capital, accumulated earnings, number of employees and tangible assets, broken down by jurisdiction.
The eighth peer review of BEPS Action 13 assesses how jurisdictions are implementing the CbC Reporting minimum standard as of April 2025 and highlights continued progress in strengthening tax transparency. Highlights include:
- Over 120 jurisdictions have already introduced legislation to impose a filing obligation on MNE groups, covering almost all MNE Groups with consolidated group revenue at or above the threshold of EUR 750 million. Remaining Inclusive Framework members are working towards finalising their domestic legal frameworks with the support of the OECD.
- Where legislation is in place, the implementation of CbC Reporting has been found largely consistent with the Action 13 minimum standard.
- More than 4900 bilateral relationships for the exchange of CbC reports are now in place.
The BEPS Action 13 peer review is an annual process, and the next peer review report will be released in the third quarter of 2026.
