OECD/G20 Base Erosion and Profit Shifting Project – Public consultation document: Review of Country-by-Country Reporting (BEPS Action 13). 6 February 2020 – 6 March 2020. Action 13 of the OECD/G20 Base Erosion and Profit Shifting Project (BEPS Action 13) established a three-tiered standardised approach to transfer pricing documentation, comprising: •a master file with high level information regarding a multinational enterprise’s(MNE group) global business operations and transfer pricing policies; •a local file with detailed transactional transfer pricing documentation specific to each jurisdiction; and •a Country-by-Country Report (CbC report) that provides annually and for each tax jurisdiction in which an MNE group does business the amount of revenue, profit before income tax and income tax paid and accrued, together with other information relevant to a high level risk assessment. The specific content of these three documents reflects an effort to balance the needs of tax administrations to have access to robust, relevant information for use in risk assessment and enforcing transfer pricing rules, against concerns from business surrounding the burden placed on MNE groups and the potential use of the information provided. Of these documents only the CbC report is covered by the BEPS Action 13 minim um standard, which all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) are committed to implement. The BEPS Action 13 report also included a mandate for a review of the BEPS Action 13 minimum standard, to be completed by the end of 2020 (the 2020 review) which would take into account matters including: • whether modifications to the content of CbC reports should be made, to require the reporting of additional or different data; • the appropriateness of the applicable revenue threshold; • the effectiveness of filing and dissemination mechanisms; and • the implementation of the BEPS Action 13 implementation package. In June 2018, the Inclusive Framework directed the OECD Committee on Fiscal Affairs’ (CFA) Working Party 6 (on the Taxation of Multinational Enterprises) and Working Party 10 (on Transparency and Exchange of Information) to work together to conduct this 2020 review and to formulate draft recommendations, if any changes need to be made. This public consultation document forms an intrinsic and essential part of this review, as a mechanism to obtain feedback from all stakeholders. Specific questions upon which comments are sought are set out in each chapter of the document. This public consultation document comprises three chapters. Chapter 1 contains general topics concerning the implementation and operation of BEPS Action 13, including the MNE group experience of CbC reporting implementation by jurisdictions, the use of CbC reports by tax administrations and other aspects of BEPS Action 13, being the master file and local file. Chapter 2 contains topics concerning the scope of CbC reporting, including the definition of an MNE group, and the level and operation of the consolidated group revenue threshold. Chapter 3 contains topics concerning the content of a CbC report, including whether aggregate or consolidated information should be provided in Table 1, whether information in Table 1 should be presented by entity rather than by tax jurisdiction, and whether additional or different information is needed. The topics discussed throughout this document reflect issues that are specifically included in the mandate for a 2020 review set out in the BEPS Action 13 report, issues where interpretative guidance issued since 2016 has been unable to result in a consistent approach to be applied by all jurisdictions, and issues that have been raised by jurisdictions or stakeholders and that can only be addressed through a change to the minim um standard, which must be agreed by the Inclusive Framework. The Inclusive Framework welcomes comments on all aspects of the BEPS Action 13 report, but specifically invites comments on the questions raised throughout this document. Interested parties are invited to send their comments no later than 18h00 (CET) on 6 March 2020, by e -mail to email@example.com in Word format (in order to facilitate their distribution to government officials). Please note that all comments on this public consultation document will be made publicly available. Comments submitted in the name of a collective “grouping” or “coalition”, or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting. Speakers and other participants at the upcoming public consultation meeting in Paris will be select ed from among those providing timely written comments on this consultation document. The public consultation meeting on the 2020 review of BEPS Action 13 will be held on 17 March 2020, at the OECD Conference Centre in Paris. The objective is to provide external stakeholders an opportunity to provide input on the ongoing work. Information on the public consultation meeting is available on the OECD website. The views and proposals included in this document do not represent the consensus views of the CFA, the Inclusive Framework or its subsidiary bodies but are intended to provide stakeholders with substantive proposals for analysis and comment.