On April 6, 2017, the Inclusive Framework on BEPS released additional guidance to provide essential information on implementation of the Country-by-Country (CbC) reporting (BEPS Action 13).

The updated CbC guidance document contains additional information clarifying several interpretation issues related to the data to be included in the CbC report as well as to the application of the model legislation contained in the Action 13 report.

The five (5) specific issues addressed in the updated guidance are as follows:

  1. the definition of revenues;
  2. the accounting principles/standards for determining the existence of and membership in a group;
  3. the definition of total consolidated group revenue;
  4. the treatment of major shareholdings; and
  5. the definition of related party for purposes of completing Table 1 of the CbC report.

The complete set of guidance relating to CbC reporting is presented in the guidance document, which will be updated for any further guidance that may be published.