Country-by-Country Reporting – CbCR (OECD)

Country-by-Country Reporting (CbCR) is a reporting obligation applicable to the largest multinational groups operating across multiple jurisdictions. The system was introduced by the OECD under BEPS Action 13 and is applied globally. CbCR provides tax authorities with information on the global allocation of income, corporate income tax, employees, and assets across countries, enabling them to assess risks related to base erosion and profit shifting. Our service ensures the full preparation of the CbC Report and CbC notifications, in compliance with OECD requirements and local regulations.

As part of the service, we prepare:

1. Verification of CbCR obligations and identification of the reporting entity: assessment of the group’s status and whether it meets the EUR 750 million consolidated revenue threshold, identification of the ultimate parent entity and reporting entity (ultimate parent / surrogate parent), identification of local filing obligations.

‍2. Preparation and review of the CbC notification (CbC-P): assistance in determining the responsible reporting entity within the group, preparation of the CbC-P notification in line with local requirements, verification of deadlines and obligations for each jurisdiction.

‍3. Preparation of the CbC-R (Country-by-Country Report): preparation of financial and operational data in accordance with OECD requirements (Tables 1–3), analysis of the allocation of revenues, employees, taxes, capital and assets by country, integration of data from local systems, group systems and financial statements, preparation of the file in OECD-compliant XML format or in line with local technical specifications.

‍4. Consistency verification with the Local File, Master File and financial statements: assessment of consistency between CbCR data and TP documentation, identification of potential discrepancies across jurisdictions, recommendations for data alignment to minimise audit risks.

‍5. Support in audit processes and responses to tax authority queries: preparation of arguments related to profit allocation, assistance in interpreting group-level data, communication with headquarters and local tax teams.

‍Client outcome: our CbCR support: ensures full compliance with OECD and local reporting requirements, minimises disputes related to profit allocation within the group, guarantees consistency between CbCR, Local File and Master File, relieves local teams from complex technical tasks, supports transparency and tax certainty across multiple jurisdictions.