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CBC Reporting & Pillar Two: A New Era of Tax Transparency

In today’s interconnected global economy, ensuring fair taxation and combating tax evasion are paramount concerns for governments worldwide. Among the array of strategies aimed at addressing these challenges, Country-by-Country Reporting (CBCR) emerges as a pivotal mechanism. Embedded within Action 13 of the Organization for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project, CBCR stands as a linchpin in fortifying transparency within multinational enterprises’ (MNEs) operations and fostering fiscal accountability.

At its core, CBCR operates on the principle of providing tax authorities with comprehensive insights into MNEs’ global income allocation, tax payments, and economic engagements across various tax jurisdictions. Through detailed disclosures of financial and jurisdictional information, CBCR empowers tax authorities to effectively identify potential transfer pricing and BEPS-related risks. Let’s delve into the components and significance of CBCR within the framework of Pillar Two of the OECD’s BEPS project.

Key Components of CBC Reporting

Basic Information: CBC reports offer tax authorities detailed insights into MNE groups, encompassing constituent entities and their respective jurisdictions. This foundational data serves as the bedrock for thorough analysis and oversight.

Financial Information: The heart of CBCR lies in the aggregation of financial data. Metrics such as revenues, profits before income tax, income tax paid, stated capital, and tangible assets provide a comprehensive snapshot of MNEs’ financial activities across borders.

Jurisdictional Information: CBC reports meticulously dissect income and taxes paid across diverse tax jurisdictions. This granular insight is indispensable for tax authorities in identifying potential tax avoidance strategies and ensuring equitable taxation practices.

Additional Insights: Beyond financial metrics, CBC reports may include supplementary information such as primary business activities of constituent entities and descriptions of major business undertakings. These insights enrich tax authorities’ understanding of MNEs’ operations and aid in assessing tax risks.

CBC Reporting and Pillar Two

Pillar Two of the OECD’s BEPS project aims to address remaining BEPS issues through the introduction of a global minimum tax and a tax on base eroding payments. CBCR complements Pillar Two by providing tax authorities with crucial data for implementing and enforcing these measures effectively. By offering transparency into MNEs’ global tax positions, CBCR supports the implementation of a global minimum tax and facilitates the identification of base eroding payments.

Jurisdictional Nuances and Compliance Obligations

It’s essential to recognize that CBC reporting requirements may vary based on jurisdictional nuances. MNEs typically submit CBC reports to the tax authority of their parent company’s jurisdiction within 12 months after the fiscal year’s conclusion. Compliance obligations further entail filing annual CBC notifications to inform tax authorities of submission details for each fiscal year’s report.

In Egypt, CBC Reporting requirements differ based on the tax residency of the Ultimate Parent Entity (UPE). Whether the UPE is tax resident in Egypt or other jurisdictions dictates the applicable threshold for CBC reporting obligations, aligning with BEPS Action 13 standards.


In summary, Country-by-Country Reporting plays a pivotal role in enhancing transparency and combating tax evasion within the global business landscape, particularly in the context of Pillar Two of the OECD’s BEPS project. By equipping tax authorities with comprehensive insights into MNEs’ operations and global tax positions, CBCR reinforces fiscal transparency and accountability. Adherence to CBC reporting requirements is not only imperative for regulatory compliance but also for fostering equitable taxation practices across jurisdictions. As governments continue to collaborate on global tax reform initiatives, CBCR remains an indispensable tool in advancing fiscal integrity and transparency worldwide.

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Written By

Sohila Mahmoud - Transfer Pricing Lead

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