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Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 2)

Inclusive Framework on BEPS: Action 13

image of Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 2)

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.

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San Marino

San Marino was first reviewed during the 2017/2018 peer review. This report is supplementary to San Marino’s 2017/2018 peer review report (OECD, 2018[1]). Since the last peer review, San Marino has introduced primary legislation in order to implement CbC Reporting requirements. The filing obligation for a CbC report in San Marino applies to reporting fiscal years commencing on or after 1 January 2019.

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