Country-by-Country Reporting (CbCR) — BEPS Action 13

Country-by-Country Reporting (CbCR) is a reporting standard under BEPS Action 13 requiring multinational enterprise (MNE) groups with consolidated annual revenues of EUR 750 million or more to annually prepare a country-by-country report (CbC Report). This report contains key financial and tax data for each tax jurisdiction in which the group operates, including revenue, profit before tax, taxes paid and accrued, number of employees, and tangible assets.

CbC Reports are filed by the ultimate parent entity in its jurisdiction of residence and shared with relevant tax authorities via automatic exchange of information (AEOI). They serve primarily for tax authority risk assessment, not for direct tax collection.

The concept of CbCR was advocated by NGOs and academics, notably Richard Murphy, since the 2000s. The BEPS project incorporated CbCR as part of the three-tiered transfer pricing documentation approach (Master File, Local File, CbC Report). The final report on Action 13 was published in October 2015. The OECD Council adopted its recommendation on CbCR implementation on 8 June 2016. From 2016, over 100 jurisdictions enacted CbCR into domestic law. The EU introduced CbCR on 25 May 2016 via the Administrative Cooperation Directive (DAC 4). For financial years beginning on or after 22 June 2024, public CbCR for large MNEs was also introduced in the EU (Directive 2021/2101).

CbCR applies to MNE groups with consolidated annual revenues of at least EUR 750 million in the preceding fiscal year. The obligation rests primarily on the ultimate parent entity (UPE) in its jurisdiction of residence. Secondary or subsidiary filing obligations apply where the UPE jurisdiction has no CbCR regime or no AEOI agreement with the relevant jurisdiction (local filing or surrogate filing). The CbC Report is exchanged via bilateral or multilateral AEOI arrangements.

• Prepare a CbC Report covering each tax jurisdiction of the MNE group
• Disclose revenue, profit/loss before tax, income tax paid and accrued per country
• State equity, retained earnings, number of employees, and tangible assets
• List all constituent entities and their tax residency
• File the CbC Report within 12 months of fiscal year end
• Automatic exchange of the report with relevant tax authorities (AEOI)
• Notify local tax authority of the filing entity (notification obligation)
• Filing in the standardised OECD CbCR XML schema (CbC XML Schema)
• Confidentiality and appropriate use: CbC Reports may only be used by tax authorities for risk assessment and transfer pricing analysis (appropriate use conditions)

5 corrections:
- Public CbCR: 'from 2024' imprecise
- DAC4 date wrong: 27 June 2016 instead of 25 May 2016
- MCAA CbCR date wrong: 12 June 2017 instead of 27 January 2016
- Grammar error: 'fuer jede Steuergebiet' instead of 'jedes'
- key_requirements_de: same gender error
2 updates:
- Number of CbCR countries outdated: 'over 80' too low
- Official URL old OECD scheme
3 clarifications.
2 notes.