BEPS
BEPS
TaxNewsFlash-BEPS — KPMG's reports of developments of interest to multinationals on the OECD's base erosion and profit shifting (BEPS) initiative and tax transparency.
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BEPS Action 13: Latest country implementation update
Recent Articles
June 2019
20 Jun - Australia: Update on effects of MLI on Australian tax treaties
17 Jun - KPMG report: BEPS Actions 8-10, aligning transfer pricing outcomes with value creation
13 Jun - India: Union Cabinet approves ratification of MLI
12 Jun - Bahamas: Status of country-by-country reporting and notification
10 Jun - Slovakia: MLI and real estate clause in tax treaties
May 2019
April 2018
March 2019
27 Mar - India: Arrangement for country-by-country report exchanges with United States is signed
15 Mar - India: Agreement with United States, exchange of country-by-country reports
14 Mar - Peru: Extended deadlines for filing country-by-country reports for 2017, 2018
12 Mar - Peru: Tax authorities communication regarding local filing of country-by-country reports for FY 2017
8 Mar - OECD: KPMG comments concerning consultation on tax challenges of digitalisation
6 Mar - France: Draft proposal for digital services tax
1 Mar - UK: HMRC profit-diversion compliance facility; verifying transfer pricing and BEPS compliance
February 2019
27 Feb - United States: IRS reminders on filing country-by-country reports on Form 8975
19 Feb - Luxembourg: BEPS multilateral instrument (MLI) update
19 Feb - OECD: Comment period extended, tax challenges of digitalisation
13 Feb - Netherlands: BEPS multilateral instrument (MLI) update
13 Feb - OECD: Public consultation of tax challenges of digitalisation, March 2019
8 Feb - United States: Statistics of country-by-country reports for 2016
7 Feb - Singapore: Effects of BEPS multilateral instrument (MLI) on tax treaties
January 2019
31 Jan - Peru: Status of country-by-country report exchanges under “MCAA CbC”
31 Jan - Hong Kong: Reminder of country-by-country notification, reporting requirements
30 Jan - OECD: Initial impressions about digital economy project
29 Jan - OECD: Initiative on tax challenges of digitalisation—“BEPS 2.0”
29 Jan - OECD: Progress report on harmful tax practices (BEPS Action 5)
15 Jan - OECD: Comparisons of corporate tax revenue, tax rates
7 Jan - Lithuania: New transfer pricing documentation requirements in 2019
2018 Articles
December 2018
26 Dec - India: Country-by-country reporting deadline extended
13 Dec - Saudi Arabia: Draft transfer pricing rules
13 Dec - Argentina: Country-by-country reporting requirements clarified, Argentine subsidiaries of MNE groups
12 Dec - Qatar: Additional country-by-country reporting guidance, notification filing deadline extended
November 2018
27 Nov - Uruguay: New transfer pricing documentation requirements
26 Nov - China: Country-by-country reporting compliance burden for certain outbound MNEs alleviated
15 Nov - OECD: Peer review of dispute resolution (MAP); BEPS Action 14
15 Nov - OECD: Update on preferential regimes, zero-tax jurisdictions
14 Nov - OECD: Report clarifying effect of MLI on tax treaties
12 Nov - Argentina: Country-by-country reporting guidance updated, modified
12 Nov - Asia Pacific: Focus on transfer pricing, considerations for MNEs
12 Nov - Peru: Extended deadline for submitting country-by-country report for 2017
7 Nov - Saudi Arabia: Effects of BEPS multilateral instrument (MLI) on tax treaties
October 2018
30 Oct - Malaysia: FAQs on country-by-country reporting, sample notification letters
25 Oct - Argentina: Country-by-country reporting, domestic subsidiaries of U.S. multinational entities
23 Oct - Costa Rica: Proposed changes to country-by-country reporting rules
19 Oct - OECD: Practice notes for developing countries, BEPS risks in mining
1 Oct - Australia: BEPS multilateral instrument (MLI) ratified
1 Oct - Japan: Effects of BEPS multilateral instrument (MLI) on existing tax treaties
September 2018
27 Sep - Andorra: Country-by-country reporting and notification rules
27 Sep - OECD: Multilateral instrument (MLI) ratification by Australia, France, Japan, Slovak Republic
18 Sep - Nigeria: Public notice published, country-by-country reporting regulations
18 Sep - OECD: Saudi Arabia signs BEPS multilateral convention
18 Sep - United States: IRS reminders relating to Form 8975 “Country-by-Country Report”
13 Sep - OECD: Updated country-by-country reporting guidance; dividends received, employee numbers
12 Sep - Malta: Reminder to file country-by-country reporting notification
August 2018
31 Aug - OECD: BEPS Action 14 peer review reports, tax dispute resolution
31 Aug - New Zealand: Draft guidance for implementing BEPS legislation
23 Aug - OECD: Former Yugoslav Republic of Macedonia joins BEPS inclusive framework
3 Aug - Peru: Country-by-country reports, transfer pricing documentation due in November 2018
July 2018
25 Jul - United States: IRS updates country-by-country reporting guidance, information
24 Jul - Belgium: Civil penalties for transfer pricing documentation compliance failures
23 Jul - OECD: Annual report on status of BEPS Inclusive Framework
13 Jul - Nigeria: Country-by-country reporting guidelines
12 Jul - France: Transfer pricing documentation requirements, clarified and detailed
11 Jul - Luxembourg: Bill to ratify multilateral instrument (MLI) into domestic law
6 Jul - France: Update on multilateral instrument (MLI) ratification
6 Jul - New Zealand: New BEPS law enacted, includes transfer pricing measures
5 Jul - India: Guidance on confidentiality, appropriate use of country-by-country reports
3 Jul - Nigeria: Transfer pricing update, including country-by-country reporting
3 Jul - OECD: BEPS discussion draft, transfer pricing aspects of financial transactions
June 2018
27 Jun - OECD: Kazakhstan, Peru, UAE sign BEPS multilateral convention (MLI)
21 Jun - Belgium: Transfer pricing documentation, reminder of due dates
21 Jun - Nigeria: Country-by-country reporting regulations are published
6 Jun - Canada: OECD peer review of country-by-country reporting
6 Jun - New Zealand: BEPS implementing legislation update; transfer pricing and thin capitalisation rules
May 2018
24 May - OECD: First peer reviews of country-by-country reports, in advance of June 2018 rollout
18 May - United States: New country-by-country reporting FAQs, filing information
18 May - Latvia: Transfer pricing documentation; focus on Master and Local files
17 May - OECD: Review of 11 preferential regimes, BEPS inclusive framework members
16 May - OECD: UAE joins BEPS inclusive framework
14 May - South Africa: Penalties for non-compliance; country-by-country reporting, transfer pricing returns
11 May - OECD: Bahrain, Saint Lucia join BEPS inclusive framework
10 May - Taiwan: Country-by-country reporting for 2017 corporate income tax return
1 May - Australia: ATO's final draft, Australian Local file requirements for 2018 tax years
April 2018
27 Apr - Hong Kong: Transfer pricing amendments to the “BEPS bill”
18 Apr - OECD: Developing countries addressing BEPS; mining sector’s excessive interest deductions
13 Apr - India: Proposed advance ruling changes, implementing BEPS Action 5 (permanent establishments)
10 Apr - OECD: Transfer pricing “country profiles” add new profiles for 14 countries
4 Apr - Luxembourg: Ratification of BEPS multilateral instrument expected in 2018
March 2018
26 Mar - Argentina: Country-by-country notification deadline extended to 2 May 2018
22 Mar - OECD: Additional guidance on attribution of profits to permanent establishments (BEPS Action 7)
21 Mar - EU: Proposals for taxation of digital businesses
20 Mar - Nigeria: Country-by-country reporting to be added to transfer pricing rules
20 Mar - Netherlands: Update about multilateral instrument (MLI)
16 Mar - OECD: Interim report, tax challenges from digitalisation (BEPS)
16 Mar - Poland: Extended deadline for transfer pricing documentation requirements
13 Mar - EU: Disclosure rules, reportable cross-border arrangements by tax advisers
12 Mar - OECD: Improving tax dispute resolution mechanisms under BEPS Action 14, including MAP access
7 Mar - EU: Aggressive tax planning; focus on interest, royalties, transfer pricing
6 Mar - Mauritius: Country-by-country reporting regulations, effective July 2018
February 2018
26 Feb - Kazakhstan: Transfer pricing documentation includes country-by-country reporting
26 Feb - Lithuania: New transfer pricing documentation rules in draft order
22 Feb - Italy: Draft transfer pricing regulations released for public consultation
21 Feb - Canada: BEPS Multilateral Instrument (MLI) ratification process initiated
13 Feb - Costa Rica: Details on country-by-country reporting requirements
13 Feb - Poland: Guidance on preparation of transfer pricing documentation
8 Feb - OECD: Update on BEPS implementation, country-by-country reporting
6 Feb - Malaysia: Revisions, updates to APA rules and MAP guidelines
2 Feb - India: Transfer pricing proposals in 2018 budget, country-by-country reporting clarifications
January 2018
24 Jan - OECD: Multilateral risk assessment pilot program, transfer pricing information
18 Jan - United States: Updated FAQs, information about country-by-country reporting
9 Jan - Taiwan: Safe harbor exemption, Master file and country-by-country reporting submissions
5 Jan - France: Transfer pricing documentation measures included in new law
5 Jan - Malaysia: Country-by-country reporting update
3 Jan - Argentina: Transfer pricing rules reformed, revised
2 Jan - Hong Kong: BEPS legislation, move towards enhanced transfer pricing enforcement regime
2017 Articles
December 2017
26 Dec - China: Guidance clarifying country-by-country reporting, information exchange
22 Dec - Austria: Country-by-country reporting by year-end
21 Dec - Switzerland: Country-by-country reporting for FY 2016, filing is due 31 December 2017
21 Dec - Malaysia: Reminder of approaching country-by-country reporting notification deadline
21 Dec - OECD: Jurisdictions implement final regulations for first filings of country-by-country reports
18 Dec - OECD: 2017 update to the “Model Tax Convention” addresses BEPS
15 Dec - Hungary: Country-by-country reporting and notification requirements, deadlines
14 Dec - Czech Republic: Review of first-phase common errors, country-by-country reporting
13 Dec - New Zealand: BEPS implementing legislation would affect related-party loans, transfer pricing rules
12 Dec - Italy: Deadline for filing country-by-country reports postponed
11 Dec - Greece: Guidelines for country-by-country reports
8 Dec - South Africa: Country-by-country reporting returns, due date extended
4 Dec - OECD: First review of BEPS Action 5 minimum standard, spontaneous exchange on tax rulings
1 Dec - Italy: Implementing guidelines for country-by-country reports
November 2017
30 Nov - OECD: Updated guidance on country-by-country reporting (BEPS Action 13)
28 Nov - Thailand: Preferential tax regimes, status under BEPS “harmful tax practices” standard
27 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2016
23 Nov - OECD: 2017 update to the OECD Model Tax Convention approved
23 Nov - Australia: ATO grants extension of time to file country-by-country statements
22 Nov - Taiwan: Transfer pricing documentation to include country-by-country reporting, Master file
21 Nov - Romania: Guidance on form for country-by-country reporting
21 Nov - United States: IRS update to jurisdiction status table, country-by-country reporting
20 Nov - Peru: Transfer pricing documentation—country-by-country reporting, Master file, Local file
13 Nov - Singapore: Tax incentives meet international BEPS standards
7 Nov - Costa Rica: Country-by-country reporting, draft resolution released
3 Nov - Italy: Agreement for automatic exchange of country-by-country reports with United States
2 Nov - India: Final rules on country-by-country reporting, Master file requirements
1 Nov - Bulgaria: Country-by-country reporting procedure, format approved
October 2017
26 Oct - India: First country-by-country report due date extended to 31 March 2018
25 Oct - OECD: Public consultation on 1 November, tax challenges of digitalisation
24 Oct - OECD: Guidance on VAT and consumption tax collection, cross-border sales (BEPS Action 1)
20 Oct - Hungary: Country-by-country reporting form, released by tax authority
18 Oct - OECD: Comments to tax challenges of digitalization (BEPS Action 1)
18 Oct - Poland: Country-by-country reporting, template of electronic form available
16 Oct - OECD: Update on BEPS project; harmful tax incentives being dismantled
11 Oct - Czech Republic: Country-by-country reporting implemented
11 Oct - OECD: Country-by-country reporting implementation status, exchange relationships (BEPS Action 13)
10 Oct - Greece: Country-by-country reporting update
9 Oct - India: Proposed country-by-country reporting, Master file rules
September 2017
29 Sep - Japan: Tax agency’s Q&A guidance on mutual agreement procedure (MAP)
26 Sep - OECD: First peer reviews, implementation of BEPS tax dispute resolution mechanisms (including MAPs)
26 Sep - Argentina: Country-by-country reporting rules
25 Sep - OECD: Tax administrations to discuss BEPS, information exchanges
20 Sep - United States: IRS updates country-by-country reporting guidance
20 Sep - OECD: IT guidelines for country-by-country reporting exchanges
18 Sep - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits
14 Sep - Lithuania: Country-by-country reporting rules
6 Sep - OECD: New guidance on country-by-country reporting (BEPS Action 13)
August 2017
30 Aug - United States: List of countries for country-by-country reporting data exchanges
29 Aug - Taiwan: Country-by-country reporting requirements in draft transfer pricing documentation rules
22 Aug - Country-by-country reporting: Timeline of notification requirements per country
18 Aug - UK: Updated HMRC guidance for filing country-by-country reports
17 Aug - Bulgaria: Rules for country-by-country reporting
17 Aug - Greece: Country-by-country reporting measures are enacted
17 Aug - OECD: Nigeria signs multilateral instrument (MLI) agreement
14 Aug - Latvia: Transfer pricing reporting requirements include country-by-country reports
11 Aug - United States: IRS now accepting country-by-country report (Form 8975)
4 Aug - New Zealand: Update on BEPS, transfer pricing proposals
1 Aug - Hong Kong: Transfer pricing legislation expected by late 2017; findings of BEPS consultation
1 Aug - India: Country-by-country reporting, update
1 Aug - OECD: Draft toolkit, addressing taxation of offshore indirect transfers of assets
July 2017
27 Jul - OECD: BEPS Action 2 report; recommendations on branch mismatches
20 Jul - Czech Republic: Legislation for implementing country-by-country reporting advances
18 Jul - OECD: Additional guidance for country-by-country reporting (BEPS Action 13)
11 Jul - OECD: Cameroon signs multilateral convention to implement BEPS
11 Jul - OECD: Draft contents of 2017 update to Model Tax Convention
10 Jul - OECD: Updates to transfer pricing guidelines for multinational enterprises
10 Jul - Asia Pacific: Country-by-country reporting; implementation issues
7 Jul - EU: European Parliament adopts report on proposal for “public” country-by-country reporting
7 Jul - United States: IRS provides FAQs on country-by-country reporting
5 Jul - OECD: Report on status of CRS, BEPS for G20 leaders
5 Jul - OECD: Comments on BEPS discussion draft; guidance on hard-to-value intangibles
5 Jul - OECD: Mauritius signs the BEPS multilateral convention
June 2017
30 Jun - United States: Form 8975 and instructions for country-by-country reporting; IRS launches CbC webpage
28 Jun - OECD: Update on international tax transparency
27 Jun - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits
23 Jun - KPMG reports: Effects of multilateral instrument implementing BEPS in various tax treaties
23 Jun - Romania: Country-by-country reporting added to tax law
22 Jun - OECD: BEPS inclusive framework, update on country-by-country reporting exchanges
21 Jun - EU: Proposed mandatory disclosure of reportable tax planning cross-border arrangements
2016 Articles
December 2016
28 Dec - Luxembourg: Country-by-country reporting, notification procedure
22 Dec - OECD: Updated guidance released, BEPS Action 4 and interest deductions and other financial payments
20 Dec - Luxembourg: Country-by-country reporting law passed by parliament
15 Dec - Slovakia: Country-by-country reporting introduced in new government bill
13 Dec - France: Country-by-country public financial reporting held unconstitutional
9 Dec - Denmark: Country-by-country notification requirements
7 Dec - Australia: Country-by-country reporting Q&As
5 Dec - Norway: Country-by-country reporting pursuant to BEPS Action 13
5 Dec - OECD: BEPS guidance on country-by-country reporting, country-specific information on implementation
5 Dec - OECD: Mutual agreement procedure (MAP) statistics for 2015
November 2016
30 Nov - Finland: Country-by-country reporting, Master file, Local file requirements
25 Nov - OECD: Macau, Mauritius and Ukraine join BEPS inclusive framework
24 Nov - OECD: Multilateral convention to implement BEPS into tax treaties
22 Nov - Netherlands: Country-by-country reporting, 2016 notification deadline is extended
17 Nov - Brazil: Initial BEPS guidance on dispute resolution; CbC consultation
3 Nov - OECD: Panama joins BEPS inclusive framework
1 Nov - OECD: Taxpayer questionnaire, input into MAP process
October 2016
31 Oct - OECD: Reminder about business survey on tax certainty; 16 December cutoff
31 Oct - OECD: BEPS Action 14, peer reviews schedule
28 Oct - Hong Kong: Consultation on formal transfer pricing regime
28 Oct - OECD: Automatic exchange of tax information agreement, signed by Cook Islands
27 Oct - OECD: Panama signs agreement for automatic exchange of tax information
25 Oct - Channel Islands: Country-by-country reporting, draft regulations in Jersey
24 Oct - Singapore: Country-by-country reporting guide
21 Oct - Ireland: Irish Revenue updates FAQs on country-by-country reporting
21 Oct - Cyprus: Amendments to intellectual property tax regime, implementing BEPS recommendations
21 Oct - OECD: Five jurisdictions agree to automatic exchange of country-by-country reports
21 Oct - Vietnam: Draft decree to implement transfer pricing standards, BEPS recommendations
20 Oct - OECD: MAP peer review, for resolving treaty-related disputes (BEPS Action 14)
19 Oct - OECD: Andorra joins BEPS inclusive framework
18 Oct - OECD: Business survey; tax certainty to support G20 tax agenda
13 Oct - Australia: Involving human resources, mobility professionals in country-by-country reporting
10 Oct - France: Decree implementing country-by-country reporting
Taxation of the Digitalized Economy
KPMG's reports of developments concerning the tax treatment of the digital economy, including digital services tax and the taxation of online, remote sales
>> Read more
November 2016
September - October 2016
31 Oct - OECD: Reminder about business survey on tax certainty; 16 December cutoff
31 Oct - OECD: BEPS Action 14, peer reviews schedule
28 Oct - Hong Kong: Consultation on formal transfer pricing regime
28 Oct - OECD: Automatic exchange of tax information agreement, signed by Cook Islands
27 Oct - OECD: Panama signs agreement for automatic exchange of tax information
25 Oct - Channel Islands: Country-by-country reporting, draft regulations in Jersey
24 Oct - Singapore: Country-by-country reporting guide
21 Oct - Ireland: Irish Revenue updates FAQs on country-by-country reporting
21 Oct - Cyprus: Amendments to intellectual property tax regime, implementing BEPS recommendations
21 Oct - OECD: Five jurisdictions agree to automatic exchange of country-by-country reports
21 Oct - Vietnam: Draft decree to implement transfer pricing standards, BEPS recommendations
20 Oct - OECD: MAP peer review, for resolving treaty-related disputes (BEPS Action 14)
19 Oct - OECD: Andorra joins BEPS inclusive framework
14 Oct - UK: Practical issues that businesses may face concerning country-by-country reporting
13 Oct - Australia: Involving human resources, mobility professionals in country-by-country reporting
10 Oct - France: Decree implementing country-by-country reporting
29 Sep - Hong Kong: Incentives for intra-group financing activities, corporate treasury centres
28 Sep - Channel Islands: Country-by-country reporting, consultation in Guernsey
28 Sep - OECD: Public consultation on BEPS-related transfer pricing matters, 11-12 October
28 Sep - Sweden: Country-by-country reporting provisions in budget bill for 2017
27 Sep - Australia: Country-by-country reporting exemption guidance
23 Sep - OECD: Comments on “branch mismatch structures” under BEPS Action 2
20 Sep - Denmark: New executive order on country-by-country reporting
16 Sep - Russia: Country-by-country reporting requirements, transfer pricing documentation
15 Sep - OECD: Comments on discussion draft, interest from banking and insurance under BEPS Action 4
13 Sep - United States: EC state aid investigations show need for tax reform
9 Sep - UK: Public country-by-country reporting, amendment to Finance Bill 2016
8 Sep - New Zealand: Proposal, implementing BEPS Action 2 hybrid mismatch recommendations
6 Sep - OECD: Status report on BEPS for G20 leaders
1 Sep - Brazil: Automatic exchange of country-by-country reports
June 2016
30 Jun - OECD: New inclusive framework, 80+ countries at BEPS meeting
29 Jun - United States: Initial description of country-by-country reporting final regulations
29 Jun - OECD: Guidance on implementation of country-by-country reporting
29 Jun - United States: Country-by-country reporting, final regulations (text)
28 Jun - New Zealand: Recommendations for foreign trusts, inbound investment, BEPS proposals
28 Jun - OECD: Offshore tax evasion convention signed by Dominican Republic, Nauru
24 Jun - Singapore: Country-by-country reporting
21 Jun - EU: Agreement on directive reached, new tax avoidance rules
20 Jun - Finland: Transfer pricing documentation, country-by-country reporting draft legislation
16 Jun - OECD: Webcast discussions about BEPS, tax transparency
15 Jun - OECD: BEPS amendments incorporated into Transfer Pricing Guidelines
2 Jun - KPMG’s initial analysis of OECD discussion draft: Development of multilateral instrument
2 Jun - OECD: Jamaica, Uruguay sign tax-assistance convention, Brazil completes ratification
1 Jun - OECD: Multilateral instrument to implement tax treaty-related BEPS measures, request for comments
February 2016
29 Feb - OECD: Draft changes to model treaty; residence of pension funds
26 Feb - Jersey: Consultation on country-by-country reporting
24 Feb - Africa: Regional focus on BEPS
23 Feb - OECD: Non-member countries may join as “BEPS associates”
22 Feb - KPMG report: Initial analysis of 2016 U.S. model treaty
22 Feb - New Zealand: Implementing AEOI regime, exchange of transfer pricing rulings
17 Feb - New U.S. model income tax treaty (2016) is released
11 Feb - US: Treasury letter to EC on state aid investigations
11 Feb - Australia: Consultation on BEPS-related transfer pricing recommendations
4 Feb - Senegal: Agreements signed for tax assistance, exchange of country-by-country reports
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