OECD_CBCR & MLI

Here below the link to the updated CBC Guidance released by the OECD:

updated CbC guidance

A brief summary of the main additions:

  • Information that jurisdictions’ rules can either include or exclude constituent entity dividends from PBT (despite confirming that they must be excluded from “revenues”, the model legislation was unclear on this point so it seems different jurisdictions have taken different approaches and/or ambiguity for taxpayers has remained). Legislators are encouraged to update their rules so that taxpayers should disclose in table 3 whether such dividends (and other earnings of Constituent Entities that may be included under accounting principles) have been included in PBT.
  • Confirmation that shortening of numbers is not permissible – for example where the number is 123,456,789, this should not be shortened to 123,457 (note – this does not include guidance specifically on rounding, simply on shortening – i.e., it does not explicitly exclude rounding such to 123,457,000).
  • Confirmation that where a Constituent Entity’s financial data is included on a pro rata basis, employee numbers should also be included on a pro rata basis, with prescribed text to be included in Table 3 to explain this.
  • Table summarising interpretation concerning M&A scenarios.

MLI – Final positions were also included to the OECD’s MLI territory list.

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