Updated OECD guidance on country by country reporting (CBCR)

Mon 24 Sep 2018

The OECD has included additional points in its September 2018 edition of guidance on country by country reporting (CBCR).  The additional points cover the following areas:

• The treatment of dividends for the purposes of profit & loss before income tax, accrued income tax, and income tax paid (on a cash basis) for reporting in table 1 of the CBCR reporting document.
  • Dividends are excluded from ‘revenue’, but not profit & loss before income tax (PBIT).  Jurisdictions can take different approaches for the purposes of PBIT and the guidance recommends a disclosure note on whether dividends are included in PBIT.
  • In addition where the dividends are included in PBIT, any tax on those dividends (accrued or paid) should be reported.
• It is not acceptable to use shortened amounts (for example to the nearest thousand) when reporting figures in table 1.
• Where a constituent entity is reported on a pro-rata basis, the employee figures for that entity should also be reported on a pro-rata basis and a disclosure made to that effect in table 3.

For a further discussion of CBCR reporting requirements and their implication for transfer pricing purposes, please get in touch with a member of the Mazars international tax team.