OECD: Updated guidance on implementation of country-by-country reporting clarifies reporting of dividends
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor
Updates treatment of dividends to align with the Pillar Two anti-arbitrage rules
The Organisation for Economic Cooperation and Development (OECD) has issued an updated version of “Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13” (52 pages), a report to assist tax administrations and multinational enterprise (MNE) groups on the implementation and operation of country-by-country (CbC) reporting under base erosion and profit shifting (BEPS) Action 13.
The updated guidance will assist tax administrations and taxpayers on questions of interpretation to provide consistent implementation of the standard.
The information marked as “new” in May 2024 updates the treatment of dividends to align with the Pillar Two anti-arbitrage rules as applicable to the Transitional CbCR Safe Harbor.
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