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Country-by-country reporting for multinational enterprise groups [EU Legislation in Progress]

Written by Cécile Remeur (3rd edition),

© Maksim Kabakou / Fotolia

New proposals on transparency would provide tax authorities with comprehensive and relevant information on the activities of multinational enterprise (MNE) groups to help countries fight tax avoidance and aggressive tax planning. Action has been designed to be implemented at both international and European Union (EU) levels.

In particular, Action 13 of the OECD/G20 BEPS (Base erosion and profit shifting) action plan includes a requirement that MNEs provide all relevant governments with information on their global allocation of income, economic activity and taxes paid using a common template.

The European Commission has proposed to amend the Directive on administrative cooperation in the field of taxation (DAC) to implement BEPS action 13 on country-by-country reporting (CBCR) in the EU. CBCR would be added to the categories of information subject to automatic exchange of information between Member State tax administrations, under the DAC’s exchange mechanism. As a tax measure, Parliament is only consulted and the proposal has to be adopted by the Council.


Proposal for a Council Directive amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation

Committee responsible:


Economic and Monetary Affairs (ECON)

Dariusz Rosati (EPP, Poland)

COM(2016) 25 of 28.01.2016

procedure ref.: 2016/0010(CNS)


Next steps expected: Council Directive (EU) 2016/881
of 25 May 2016
OJ L 146/8, 3.6.2016


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