UK and International Tax news

BEPS 13 – OECD Releases CbC Reporting Implementation Status Update

Friday 13th October 2017

The OECD has recently released an implementation status update in respect of BEPS Action 13 through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports.

To date, 65 jurisdictions have signed the CbC MCAA, which sets out conditions and operational aspects for the exchange of CbC Reports under the multilateral convention on mutual administrative assistance in tax matters. Over forty of these jurisdictions have already provided notifications to the Co-ordinating Body Secretariat, setting out the other signatories with which they intend to have an agreement for the exchange of CbC Reports.

CbC Reports will be exchanged automatically between EU Member States under Council Directive 2016/881/EU (referred to as “DAC 4”). In total, this represents over 1000 exchange relationships between jurisdictions.

In addition, the United States has now signed 27 bilateral competent authority agreements for the exchange of CbC Reports under Double Tax Conventions or Tax Information Exchange Agreements, with more under negotiation. 

The full list of automatic exchange relationships now in place together with an update on the implementation of the domestic legal framework for CbC reporting is available on the OECD website.

The OECD expects more jurisdictions will nominate partners with which they will undertake the automatic exchange of CbC Reports under the CbC MCAA in the coming weeks.

Regular updates will be published by the OECD on its website on exchange relationships to provide clarity for MNE Groups and tax administrations.

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