The Organisation for Economic Cooperation and Development (OECD) has issued its annual peer review report for the BEPS Action 13 minimum standard, covering 138 jurisdictions that provided legislation and/or information regarding the implementation of country-by-country (CbC) reporting.
Key findings from the OECD report (September 16, 2024) include:
- Domestic legal and administrative framework: Over 115 jurisdictions have established a domestic legal framework for CbC reporting, including a number of jurisdictions that have approved final legislation awaiting official publication. Nineteen (19) jurisdictions have received general recommendations to establish or finalize their domestic legal or administrative frameworks, while 37 jurisdictions received one or more recommendations for improvements to specific areas of their framework.
- Exchange of information framework: Among the jurisdictions included in the review, 93 jurisdictions have multilateral or bilateral competent authority agreements in place.
- Confidentiality: Of the jurisdictions included in the review, 99 have undergone an assessment by the Global Forum on Transparency and Exchange of Information for Tax Purposes concerning confidentiality and data safeguards in the context of implementing the automatic exchange of information (AEOI) standard, and did not receive any action plan.
- Appropriate use: Eighty-four (84) jurisdictions have provided detailed information, allowing the Inclusive Framework to obtain sufficient assurance that measures are in place to ensure the appropriate use of CbC reports.
Certain jurisdictions, including the Cook Islands, Fiji, Kuwait, Moldova, Philippines, Saint Kitts and Nevis, and Samoa, are not included in the review. These jurisdictions either joined the Inclusive Framework after October 1, 2024, or opted out of the review.