The OECD has released additional guidance on the implementation of Country-by-Country (CbC) reporting (BEPS Action 13) which aims to clarify a number of issues for tax administrations and MNE Groups.

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 published a compilation of the approaches adopted by member jurisdictions of the Inclusive Framework with respect to issues where the guidance allows for alternative approaches. These documents will continue to be updated with any further guidance that may be agreed according to the OECD.