Strategizing Multinational Tax Risks

OECD has updated guidelines for several aspects of Country-by-Country (CbC) reporting, including:

• Dividends included in pre-tax book income
• Definition of revenues and taxes paid
• Aggregate data in one jurisdiction/eliminations
• Accumulated earnings/loss
• Treatment of major shareholdings / ownership by multiple groups
• Short accounting periods
• Parent surrogate filing

As the 2017 CbC report is almost due for US calendar-year taxpayers, it is imperative to review the OECD guidelines to ensure year-to-year consistency, with relevant statements attached for transparency.

A link to the guidelines is attached for reference.

Click to access guidance-on-the-implementation-of-country-by-country-reporting-beps-action-13.pdf