The OECD recently published Guidance on the Implementation of Country-by-Country (CbC) Reporting. A key outcome of the BEPS project is the adoption of country-by-country reporting, as set out in the 2015 BEPS Report on Action 13 “Transfer Pricing Documentation and Country-by-Country Reporting”.

Under CbC reporting, Multi National Enterprises (MNEs) are required to provide aggregate information annually in each jurisdiction where they do business relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group. It will also cover information about which entities do business in a particular jurisdiction and the business activities each entity engages in.

In Finance Act 2015, Ireland introduced section 891H TCA 1997 which provides for CBC reporting and Revenue released its CbC reporting FAQs.