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Published on August 3, 2017
The OECD published additional guidelines on 18 July 2017 in connection with the implementation of country-by-country reporting (CbCR). These guidelines show a framework in which tax authorities and business groups can orient themselves equally.
The supplementary directives are intended to introduce a model legislation which obliges companies to provide aggregated reporting to the competent authorities, irrespective of whether transactions were cross-border with affiliates or with independent companies.
In addition, the OECD provides the opportunity for ultimate group that have an integrated ERP system to consolidate fiscal financial data to aggregate the financial data of related companies and to pass them on to the authorities within the framework of the CbCR.
If a company is part of more than one company group (such as a joint venture), this is to be assessed and allocated to the CbCR threshold of € 750 million according to the accounting rules applicable to each independent group of companies.
Companies should, in order to avoid or reduce tax risks, analyze the supplementary remarks with regard to the CbCR at an early stage and take countermeasures.
Michael Scharf
Partner
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