OECD/G20 Base Erosion and Profit Shifting Project Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 2) Inclusive Framework on BEPS: Action 13: Inclusive Framework on BEPS: Action 13

Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity. This unprecedented information on MNE Groups' operations across the world will boost tax authorities' risk-assessment capabilities. The Action 13 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review process. The peer review of the Action 13 Minimum Standard is proceeding in stages with three annual reviews in 2017, 2018 and 2019. The phased review process follows the phased implementation of CbC Reporting. Each annual peer review process will therefore focus on different aspects of the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. This second annual peer review report reflects the outcome of the second review which considered all aspects of implementation. It contains the review of 116 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting Foreword Abbreviations and acronyms Executive summary Context of Country-by-Country Reporting Scope of this review Key findings Next steps Chapter 1. The review of the BEPS Action 13 minimum standard on Country-by-Country Reporting 1.1. Background 1.2. Outline of the key aspects assessed in the annual report Notes Chapter 2. Peer review reports Andorra Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Angola Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Anguilla Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Argentina Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Aruba Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Australia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Austria Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate Use Summary of recommendations on the implementation of Country-by-Country Reporting Notes The Bahamas Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Bahrain Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Barbados Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Belgium Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Belize Summary of key findings Part A: The domestic legal and administrative framework (a) Parent entity filing obligation (b) Scope and timing of parent entity filing (c) Limitation on local filing obligation (d) Limitation on local filing in case of surrogate filing (e) Effective implementation Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Benin Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Bermuda Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Botswana Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Brazil Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes British Virgin Islands Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Brunei Darussalam Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Bulgaria Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Cameroon Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Canada Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Cayman Islands Summary of key findings Part A: The domestic legal and administrative framework (a) Parent entity filing obligation (b) Scope and timing of parent entity filing Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Chile Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes China (People’s Republic of) Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Colombia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Congo Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Costa Rica Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Côte d’Ivoire Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Croatia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Curaçao Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Czech Republic Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Democratic Republic of the Congo Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Denmark Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Djibouti Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Egypt Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Estonia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Finland Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes France Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Gabon Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Georgia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Germany Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Greece Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Guernsey Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Haiti Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Hong Kong (China) Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Hungary Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Iceland Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes India Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Indonesia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Ireland Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Isle of Man Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Israel Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Italy Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Jamaica Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Japan Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Jersey Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Kazakhstan Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Kenya Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Korea Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Latvia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Liberia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Liechtenstein Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Lithuania Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Luxembourg Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Macau (China) Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Malaysia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Maldives Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Malta Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Mauritius Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Mexico Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Monaco Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Mongolia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Montserrat Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Netherlands Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes New Zealand Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Nigeria Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes North Macedonia (Republic of) Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Norway Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Oman Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Pakistan Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Panama Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Papua New Guinea Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Paraguay Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Peru Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Poland Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Portugal Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Qatar Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework (a) Exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Romania Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Russia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Saint Lucia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting San Marino Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Saudi Arabia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Senegal Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Serbia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Seychelles Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Note Sierra Leone Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Singapore Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Slovak Republic Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Slovenia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes South Africa Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Spain Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Sri Lanka Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Sweden Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Switzerland Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Thailand Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Trinidad and Tobago Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Tunisia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Turkey Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Turks and Caicos Islands Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Conclusion Summary of recommendations on the implementation of Country-by-Country Reporting Notes Ukraine Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting United Arab Emirates Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes United Kingdom Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes United States Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of country-by-country reporting Notes Uruguay Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Notes Viet Nam Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting Zambia Summary of key findings Part A: The domestic legal and administrative framework Part B: The exchange of information framework Part C: Appropriate use Summary of recommendations on the implementation of Country-by-Country Reporting References