Five More Countries Agree To Exchange CbC Reports
A further five countries have signed the OECD’s Multilateral Competent Authority Agreement for the automatic exchange of country-by-country (CbC) reports, bringing the total number of signatories to 44.
The Agreement allows all signatories to bilaterally and automatically exchange CbC reports with each other, as contemplated by base erosion and profit shifting (BEPS) Action 13. This will help ensure that tax administrations obtain a complete understanding of how multinationals structure their operations, while also ensuring that the confidentiality of such information is safeguarded. The latest territories to join the Agreement are: Argentina, Curacao, Georgia, Korea, and Uruguay.
The Agreement was signed by officials from these five countries at the OECD’s Committee on Fiscal Affairs’ first meeting under its new inclusive framework for non-OECD and non-G-20 territories to discuss the next steps to be taken as part of the BEPS project. The meeting was held in Kyoto, Japan, on June 30-July 1, 2016, and was attended by representatives from over 80 countries.
A particular focus of the inclusive framework is to ensure implementation of the four minimum standards arising from the BEPS project – on harmful tax practices, tax treaty abuse, CbC reporting, and dispute resolution mechanisms – which will be subject to a peer review process, alongside ongoing monitoring of the other elements of the package. The OECD said that countries have started the work to undertake the standard-setting on remaining issues including transfer pricing and interest deductibility, as well as the development of practical guidance to support consistent, global implementation of their commitments to the BEPS package.
36 countries have already formally joined the new inclusive framework on BEPS and have committed to implement the BEPS package, bringing to 82 the total number of countries participating on an equal footing in the project. The other 21 countries that attended the Kyoto meeting are likely to join the inclusive framework in the coming months.