Updated: Guidance on Country-by-Country Reporting

A closer look at the updated OECD guidelines for Country-by-Country Reporting, focusing on the treatment of dividends.

Updated: Guidance on Country-by-Country Reporting

One of the pivotal elements in the evolution of international tax compliance is the Country by Country (CbC) reporting requirement initiated by the OECD as part of its Base Erosion and Profit Shifting (BEPS) project. Recently, there has been a crucial update in the OECD guidelines, mainly focusing on item 2.7.1, which pertains to the treatment of dividends for purposes of "profit (loss) before income tax," "income tax accrued (current year)," and "income tax paid (on a cash basis)" in Table 1. This change, effective for fiscal years starting on or after January 1, 2025, aims to bring greater clarity and consistency across the reporting practices of multinational enterprises (MNEs).


What is Country-by-Country Reporting?

Introduced under Action 13 of the BEPS Action Plan, CbC reporting requires large multinational enterprises to report annually and for each tax jurisdiction in which they do business. This provides aggregate data on the global allocation of income, profit, taxes paid, and specific indicators of the location of economic activity among the tax jurisdictions in which they operate. This initiative is designed to enhance transparency for tax administrations by providing them with the necessary information to conduct high-level transfer pricing risk assessments.

The Significance of Dividend Treatment in CbC Reporting

Dividends are payments made by a corporation to its shareholders from its profits. In CbC reporting, how dividends are treated can significantly affect the reported profit before taxes, influencing a constituent entity's perceived profitability and tax liability within a multinational group. The latest guidance focuses on treating these dividends received from other constituent entities within the same group.

Updated Guidance on Dividend Treatment

The 2024 update has clarified that dividends paid between constituent entities should not be included in the profit (loss) before income tax in the recipient's jurisdiction if they are recognized as dividends in the payer's jurisdiction. This alignment ensures that the reported profit reflects operational earnings more accurately, excluding intra-group financial transfers that do not constitute genuine economic activities. Here's what the updated guidance entails:

  • Exclusion of Dividends: The guidance explicitly states that dividend payments from other constituent entities recognized as dividends in the payer's tax jurisdiction are excluded from profit (loss) before income tax. This is a significant shift aimed at standardizing the treatment across different jurisdictions, reducing the variability in reporting such transactions.
  • Clarification of Terms: How different jurisdictions interpret and implement dividend guidelines has often been ambiguous. The new guidance provides a more precise definition of such payments, aiming for uniformity in understanding and reporting.
  • Implementation and Compliance: Starting January 1, 2025, all MNEs are expected to comply with this new guideline. This advance notice gives companies ample time to adjust their internal reporting systems and ensures all stakeholders, including tax authorities and compliance departments, are on the same page.

Implications for Multinational Enterprises

The clarification and standardized treatment of dividends are likely to have several implications for MNEs:

  • Reduced Compliance Complexity: With a clearer understanding of how to treat inter-entity dividend payments, companies can streamline their reporting processes, reducing the risk of errors and non-compliance.
  • Enhanced Transparency: This update will likely improve the transparency of financial reporting and tax obligations, making it easier for tax authorities to assess and address BEPS risks.
  • Financial Planning and Operations: Understanding the tax implications and reporting requirements for dividend transactions can influence decision-making regarding capital structure and the distribution of profits within multinational groups.


The OECD's continuous refinement of the CbC reporting standards reflects its commitment to improving international tax compliance and curbing tax avoidance strategies. The latest updates regarding the treatment of dividends are a step forward in creating a more transparent, consistent, and fair framework for global tax reporting. As MNEs prepare to implement these changes, staying informed and proactive in adapting to new guidelines will be crucial in effectively navigating the complexities of international tax compliance.

For multinational corporations, tax advisors, and regulators, these updates are not just procedural but pivotal in shaping the future landscape of global tax practices.

How Trans World Compliance helps with CbC reporting

Are you ready to navigate the complexities of the new OECD CbC reporting guidelines effectively? Trans World Compliance is here to guide you through every step of the process. With our expertise in international tax compliance and a deep understanding of the latest updates, including the crucial changes to the treatment of dividends, we ensure that your reporting is accurate, compliant, and optimized for the new regulations. Don't let the nuances of the new guidelines overwhelm you. Contact Trans World Compliance today to secure peace of mind and stay ahead in your CbC reporting obligations. Let us help you turn compliance challenges into strategic advantages. Reach out now to set up a consultation and start your journey towards flawless compliance!