OECD Publishes 2026 CbC Reporting Peer Review Compilation

On October 19, the OECD released its 2026 peer review “Country-by‑Country Reporting – Compilation of 2026 Peer Review Reports”, which overviews results achieved by its members in pursuance of Base Erosion and Profit Shifting (BEPS) Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting).

This standard requires multinational entities to report annually, for each tax jurisdiction in which they do business, on the amount of revenue, profit before income tax and income tax paid and accrued, number of employees, stated capital, retained earnings and tangible assets. This edition covers 142 jurisdictions which provided information on their implementation of CbC reporting.

Key findings:

– Over 120 jurisdictions have a domestic legal framework for CbC reporting in place. A number of jurisdictions have final legislation approved that is awaiting official publication.

– 19 jurisdictions have received a general recommendation to put in place or finalize their domestic legal or administrative framework; 25 jurisdictions received one or more recommendations for improvements to specific areas of their framework.

– 110 jurisdictions have multilateral or bilateral competent authority agreements in place.

– 106 jurisdictions have undergone an assessment by the Global Forum on Transparency and Exchange of Information for Tax Purposes concerning confidentiality and data safeguards in the context of implementing the Automatic Exchange of Information standard, and did not receive any action plan.

– 94 jurisdictions have provided detailed information to demonstrate they have implemented measures to ensure the appropriate use of CbC reports.

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