OECD Issues Further CbC Guidance, Updates Preferential Regime Reviews

The OECD today released additional guidance for tax administrations and multinational corporations on the implementation of country-by-country (CbC) reporting requirement.

By Alex Cooper

The OECD today released additional guidance for tax administrations and multinational corporations on the implementation of country-by-country (CbC) reporting requirement.

The additional guidance addresses two specific issues: the definition of total consolidated group revenue and whether non-compliance with the confidentiality, appropriate use, and consistency conditions constitutes systemic failure.

The OECD also released a compilation of the approaches adopted by member jurisdictions of the Inclusive Framework on base erosion and profit shifting (BEPS) with respect to issues where the guidance allows for alternative approaches.

Preferential regime reviews

Meanwhile, the Inclusive Framework on BEPS approved updates to the results for preferential regime reviews conducted by the Forum on Harmful Tax Practices (FHTP) in connection with BEPS Action 5, on countering harmful tax practices more effectively.

The Inclusive Framework has updated the status of two Barbados’ regimes – the International financial services and the Credit for foreign currency earnings/Credit for overseas projects or services – as “in the process of being amended.” The regimes were concluded as “potentially harmful” by the Inclusive Framework in the 2017 Progress Report on Preferential Regimes, but Barbados subsequently committed to amending these regimes within the FHTP’s agreed timelines and in accordance with the criteria of the FHTP.

Additionally, Canada’s regime for international banking centres (IBCs) has now been updated to “abolished.” Canada’s IBC regime was determined to be “potentially but not actually harmful” by the FHTP in the 2004 Progress Report. Canada, however, abolished the regime in conformity with the FHTP guidance.

The author is editorial assistant, TP News