Taxand UK discuses the new guidance in the Country-by-Country reporting programme.
On 29 June 2016, the Organisation for Economic Co-operation and Development (OECD) announced additional guidance on the practical implementation of its Country-by-Country (CbC) Reporting programme, published in final form on 5 October 2015 as Action 13 of the Base Erosion and Profit Shifting (BEPS) initiative.
The larger BEPS program contains 15 intertwined initiatives that generally seek to limit base erosion and profit shifting by promoting transparency, coherence and substance in tax filings. Country-by-Country Reporting is a transparency initiative which recommends taxing authorities require taxpayers to provide aggregate annual business and financial information in each jurisdiction where they do business.
Specifically, the new CbC Reporting guidance provide clarification in these four areas:
Discover more: OECD guidance on implementation of Country-by-Country Reporting
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The accounting rules provide the governing principles for determining whether investment funds and partnerships are part of MNE Groups. As it stands, currency fluctuations after January 2015 will generally not trigger filing requirements if those fluctuations alone push group consolidated revenue above the reporting threshold of €750 million.