Reporting Implementation by O.E.C.D.

C.b.C. Reporting Implementation by O.E.C.D.: The O.E.C.D. has issued recently an update on the list of automatic exchange relationships established among various jurisdictions under the Multilateral Competent Authority Agreement on the exchange of country-by-country reports. The signatories of the relevant agreement have commenced exchanging Country by Country reports multilaterally which was initially proposed by base erosion and profit shifting Action 13.

 C.b.C. Reporting Implementation by O.E.C.D.               

The said framework according to the O.E.C.D. is set to assist ensuring that tax administrations obtain a complete understanding of how multinationals structure their operations, Moreover, it safeguards that confidentiality of such information.

Automatic Exchange Relationships

According to the OECD, more than 700 automatic exchange relationships have now been established between jurisdictions including those between European Union member states under EU Council Directive 2016/881/EU, which are committed to exchanging Country by Country reports as of 2018. The first automatic exchanges are expected to commence in June 2018. According to the OECD, partners are to be nominated by more jurisdictions and automatic exchange of  Country by Country reports shall be undertake between them in due course. Moreover, there is work in progress by some jurisdictions for the establishment of bilateral competent authority agreements. Again, these agreements are for the automatic exchange of Country by Country reports under tax treaties with specified partners or tax information exchange agreements, for example the United States.

Implementation of domestic legal framework

The O.E.C.D. in its latest publication issued also an update on the implementation of the domestic legal framework for Country by Country reporting in various jurisdictions. More specifically, information has been provided on jurisdictions that will allow surrogate filing and voluntary parent surrogate filing in addition to the steps that are being taken to address concerns about local filing being applied prior 2017.

Country by Country Reporting

This set up requires multinational enterprises to provide aggregate information annually, in each jurisdiction.This information includes the places where business is conducted and relates to the global allocation of income and taxes paid, among other indicators of the location of economic activity within the M.N.E. group. Additionally it will also include information about which entities do business in a particular jurisdiction as well as the business activities that each entity engages in.