BEPS: CbC Reporting Implementation Expected in 2016; Exchange of Information to Start in 2017

By Robert Robillard - 6 February 2015

This blogpost originally appeared on

From the OECD website:

First steps towards implementation of OECD/G20 efforts against tax avoidance by multinationals

06/02/2015 – The OECD will present the latest developments in the OECD/G20 project to combat base erosion and profit shifting (BEPS) by multinational enterprises during a G20 Finance Ministers meeting on 9-10 February in Istanbul, Turkey.

OECD and G20 countries have agreed three key elements that will enable implementation of the BEPS Project:

• a mandate to launch negotiations on a multilateral instrument to streamline implementation of tax treaty-related BEPS measures;
• an implementation package for country-by-country reporting in 2016 and a related government-to-government exchange mechanism to start in 2017;
• criteria to assess whether preferential treatment regimes for intellectual property (patent boxes) are harmful or not.

“These are important steps forward, which demonstrate that progress is being made toward a fairer international tax system,” OECD Secretary-General Angel Gurría said. “These decisions signal the unwavering commitment of the international community to put an end to base erosion and profit shifting, in line with the ambitious timeline endorsed by G20 leaders. […]”

CbC reporting will soon be a reality…

The initiative on patent boxes is somewhat entertaining, to say the least. As BEPS chug along, Italy, UK and Ireland, to name a few, have recently announced their own preferential treatment regime for intellectual property.

But of course, believers will have us think that the multilateral instrument will help streamline implementation of tax treaty-related BEPS measures…

We shall see what we shall see…

Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Transfer Pricing Chief Economist, RBRT Inc.
514-742-8086; robert.robillard “at”

RBRT Inc. is all about transfer pricing. We specialize in transfer pricing, tax treaties and other international tax matters. Our services include transfer pricing documentation (transfer pricing policies and procedures, BEPS and C-doc), transfer pricing dispute resolution, tax treaty matters including double tax relief, tax treaty-based returns and waivers, advanced pricing agreement (APA), value chain management and TP planning, transfer pricing training. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. and the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek tax advice and tax counsel from RBRT Inc. as required.