United Kingdom


  • Service: Tax
  • Type: Business and industry issue
  • Date: 08/11/2013

Country by Country Reporting 

The debate on the disclosure of information on tax continues to be high on the agenda of many governments and in boardrooms. The Organisation for Economic Co-Operation and Development (OECD)’s proposals for introducing a mandatory Country by Country Reporting (CbyCR) template to be submitted to tax authorities is fast becoming a reality. The template is part of their Action Plan on Base Erosion and Profit Shifting (BEPS) and is part of a package involving the reform of transfer pricing documentation.

OECD CbyCR  template


This report summarises (PDF 755 KB)the key points discussed at the 19 May 2014 consultation meeting, including a mock-up of the proposed template as at 18 April 2014. It is subject to further change as it goes through the approval process and further updates will follow once the final version is publicly available. As a reminder, the responses to the original consultation document issued on 30 January 2014 are available on the OECD website (external link).


KPMG in the UK partner Julie Hughff, spoke on a panel discussing the CbyCR template at the OECD International Tax Conference, in Washington DC, on 2 and 3 June 2014. The OECD and USCIB (United States Council for International Business) organised the conference, where the OECD’s Marlies De Ruiter re-confirmed the next steps in the process. The template contents will be finalised and submitted to the Committee on Fiscal Affairs (CFA) for approval in June 2014, and the OECD’s intention  is that this will be made public in September 2014 around the time of the G20 Finance Ministers meeting in Australia.


As the template implementation and submission and sharing process throws up many complex issues, further work will happen in the coming months with a recommendation being made by January 2015. We believe it is vital that implementation is coordinated as far as possible to avoid a disproportionate compliance burden falling on businesses.


It is still hard to predict precisely when this will go live in each country. However, given the political momentum, and the likely time it will take to implement new processes and technologies, we believe companies should act now to assess how they will comply. Find out how we can help (PDF 380 KB).

Other CbyCR  requirements


The OECD CbyCR template is not the only country by country reporting requirement. Our briefing document (PDF 712 KB) summarises the various other mandatory reporting requirements affecting companies in certain specific sectors. Companies in these sectors will need to comply with these regulations plus the OECD CbyCR template so will need to assess how to gather data efficiently to meet all relevant regulations.


In particular, the UK government has announced it intends to implement Chapter 10 of the EU Accounting Directive for Extractive industries for financial years commencing on or after 1 January 2015. Companies that fall within the scope of this directive will need to consider the draft legislation and start to prepare. This has not yet been updated in our document but a revised version will be available soon.


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Julie Hughff

Julie Hughff


KPMG in the UK

020 7311 3287

Email Julie

Aron Mayer

Aron Mayer


KPMG in the UK

020 7311 3262

Email Aron