On 25 September 2023 the sixth annual peer review report was issued under BEPS Action 13, looking at the implementation of the minimum standard on country by country (CbC) reporting by jurisdictions at April 2023. The report covers 136 member countries of the OECD’s Inclusive Framework on BEPS.

The Action 13 minimum standard on CbC reporting requires tax administrations to collect and exchange detailed information on the large MNEs doing business in their country. Under Action 13 countries need to collect information on the amount of revenue reported; profit before income tax; income tax paid and accrued; the stated capital; accumulated earnings; number of employees; and tangible assets. This information must be analysed for each jurisdiction in which the multinational operates.

The latest report notes that more than 110 jurisdictions have introduced legislation imposing a filing requirement on multinational groups, applying to almost all MNE Groups with consolidated group revenue above the threshold of EUR 750 million. The remaining member countries of the Inclusive Framework are continuing to finalise the details of their domestic legal frameworks with the help of the OECD.

The report notes that in countries where the appropriate legislation is in place, the implementation of CbC reporting is generally consistent with the Action 13 minimum standard. Many of the recommendations made in the first five years of peer reviews have now been implemented. The report notes that more than three thousand bilateral arrangements for the exchange of CbC reports are currently in place.

The OECD will publish the next peer review report on Action 13 in the third quarter of 2024.