Country-by-Country Report Workpaper Template (BEPS Action 13, EU CbCR)

Country-by-Country Report Workpaper: [MNE group name] FY[YYYY]

Preparation workpaper for a country-by-country (CbC) report under OECD/G20 BEPS Action 13: scope and threshold test, filing and notification plan, data sources, the three OECD tables (jurisdiction data, constituent entities and activities, additional information), reconciliation to the consolidated accounts, data quality checks, the Pillar Two Transitional CbCR Safe Harbour check, and the differences for EU public CbCR under Directive (EU) 2021/2101. Structure follows the OECD Transfer Pricing Guidelines 2022, Chapter V, Annex III, and the OECD Pillar Two side-by-side package (January 2026). Replace every [bracketed] value and every row marked Example. This is a document format, not tax, legal, accounting or financial advice. Requirements are referenced by number: obtain the guidelines or the law for the normative text.

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Revision history

Contents

• 1. Scope and threshold test
• 2. Reporting entity, filing and notification plan
• 3. Data sources and consolidation basis
• 4. Table 1: data by tax jurisdiction
• 5. Table 2: constituent entities and activities
• 6. Table 3: additional information
• 7. Reconciliation to the consolidated financial statements
• 8. Data quality checks and risk indicators
• 9. Transitional CbCR Safe Harbour check
• 10. EU public country-by-country reporting
• 11. Review, submission and retention log
• 12. Glossary and references
• Standard and licence note

1. Scope and threshold test

1.1 Threshold test

Under the BEPS Action 13 minimum standard, an MNE group files a CbC report for a fiscal year when its consolidated group revenue in the immediately preceding fiscal year was at least EUR 750m (or a near equivalent in local currency as of January 2015). Several jurisdictions express the threshold in their own currency: the United States uses USD 850m for US-parented groups filing Form 8975 (Treas. Reg. 1.6038-4), and Vietnam now uses the equivalent of EUR 750m under Decree 255/2026/ND-CP. Check local law for the threshold, the currency and the exchange rate to apply.

1.2 Scope of constituent entities

List every constituent entity: each separate business unit included in the consolidated financial statements (or that would be if its equity were traded), entities excluded only on size or materiality grounds, and every permanent establishment. Example: OST-NL, OST-DE, OST-UK, OST-US and OST-VN as in the master file; no permanent establishments; no entities excluded on materiality.

2. Reporting entity, filing and notification plan

2.1 Reporting entity

2.2 Filing and notification calendar (as of 2026-10)

Check local law: notification rules vary more than filing rules.

Secondary (local) filing is the main risk in a foreign-parented group. A local entity may have to file the full report itself when the parent jurisdiction does not require one, has no exchange agreement in effect with the local country, or has systemically failed to exchange. Review the exchange status each year, because agreements are signed and suspended over time, and record the conclusion per jurisdiction in 2.1 before the notification deadlines pass.

3. Data sources and consolidation basis

3.1 Source and conventions

3.2 Data request

The fixed asset data usually come from Fixed Asset Register (finance/fixed-asset-register); intercompany revenue comes from the intercompany matching process covered by Account Reconciliation (finance/account-reconciliation).

4. Table 1: data by tax jurisdiction

4.1 Column definitions (summary)

4.2 Table 1 data

Check: related revenues 518,120 + 116,640 = 634,760; total revenues 818,120 + 210,000 + 150,000 + 225,000 + 131,640 = 1,534,760; profit before tax 66,180 + 6,300 + 4,500 + 3,630 + 9,390 = 90,000; tax accrued 18,545 + 1,890 + 1,125 + 901 + 939 = 23,400; tax paid 17,100 + 1,750 + 1,020 + 840 + 850 = 21,560.

Tax accrued is the current tax on FY2026 taxable profits per jurisdiction, as computed in Income Tax Provision (finance/income-tax-provision, section 3.2: current tax before adjustments less credits). It excludes the FY2025 Netherlands return-to-provision credit (250) and the German uncertain tax position charge (250), which net to zero in the consolidated current tax expense of 23,400 (see section 7). Vietnam's accrued tax is 10% of profit before tax because OST-VN applies a preferential corporate income tax rate of 10% for qualifying software production (Example; check the current Vietnamese incentive law and the entity's eligibility).

The US profit before tax (3,630) is after interest of 3,120 on loan FIN-001: operating profit 6,750 (3.0% of 225,000) less 3,120.

4.3 Build-up of related-party revenues

Check: 175,000 + 125,000 + 190,000 + 12,000 + 13,000 + 3,120 = 518,120 for NL; 518,120 + 116,640 = 634,760.

5. Table 2: constituent entities and activities

The OECD template offers a fixed list of activity categories, including research and development, holding or managing intellectual property, purchasing or procurement, manufacturing or production, sales, marketing or distribution, administrative, management or support services, services to unrelated parties, internal group finance, regulated financial services, insurance, holding shares or other equity instruments, dormant, and other (with an explanation in Table 3).

Check each line against the master file functional table (section 3.5 of finance/transfer-pricing-master-file). Example: OST-VN performs research and development as a contract service provider; ticking "holding or managing IP" for it would contradict the master file.

6. Table 3: additional information

Draft text for Table 3 (Example):

• Data source: IFRS consolidation reporting packages before intra-group eliminations; same source as in prior years.
• Currency: EUR; income items translated at average rates for FY2026 (GBP 0.86, USD 1.10, VND 28,500 per EUR), balances at closing rates.
• Employees: full-time equivalents at 2026-12-31.
• Tangible assets: net book value including right-of-use assets under IFRS 16; excluding cash, intangibles and financial assets.
• Netherlands: profit reflects the parent's role as owner of the platform and brand and the bearer of development and market risks, as documented in the master file.
• Netherlands: tax accrued of 28.0% of profit before tax is above the 25.8% headline rate because share-based payments, costs of an aborted share acquisition and other items are not deductible.
• Vietnam: revenues are mainly a cost-plus development fee from the parent; low revenue per employee reflects a labour-intensive service activity. Tax accrued reflects a 10% preferential corporate income tax rate for qualifying software production.
• Intra-group dividends: none received in FY2026.

7. Reconciliation to the consolidated financial statements

Check: 1,534,760 - 634,760 = 900,000.

Explain every non-zero difference, for example unrealised profit on intra-group inventory, purchase price allocation amounts booked only at group level, or entities consolidated using a different year end. Keep the reconciliation file as evidence; it is not part of the filed report.

8. Data quality checks and risk indicators

8.1 Validation checks

8.2 Risk indicators by jurisdiction

Check (NL): 66,180 / 1,400 = 47.27; 818,120 / 1,400 = 584.4; 18,545 / 66,180 = 28.0%; 518,120 / 818,120 = 63.3%; 17,100 / 18,545 = 92.2%. VN: 939 / 9,390 = 10.0%; 850 / 939 = 90.5%. Group: 90,000 / 6,000 = 15.00; 900,000 / 6,000 = 150.0; 23,400 / 90,000 = 26.0%; 634,760 / 1,534,760 = 41.4%; 21,560 / 23,400 = 92.1%.

Example: The Netherlands shows four to five times the profit per employee of the distributors because it bears the entrepreneurial risks and owns the platform. This is consistent with the master file and is explained in Table 3. Vietnam's 10.0% tax ratio is the most visible outlier: a reviewer will ask about it, so Table 3 names the preferential rate, and the Pillar Two position is documented in section 9. Tax paid is below tax accrued in every country because final payments for FY2026 fall due in 2027; no further explanation needed.

9. Transitional CbCR Safe Harbour check

9.1 Rules in brief (as of 2026-10)

• The safe harbour was agreed by the OECD/G20 Inclusive Framework in December 2022 for a transition period. The side-by-side package (approved in January 2026) extended it by one year: it now covers fiscal years beginning on or before 31 December 2027, excluding fiscal years ending after 30 June 2029.
• Transition rate for the simplified ETR test: 15% for fiscal years beginning in 2023 and 2024, 16% for 2025, and 17% for 2026 and 2027.
• De minimis test: total revenues below EUR 10m and profit before tax below EUR 1m in the jurisdiction.
• Routine profits test: profit before tax not above the substance-based income exclusion (payroll and tangible asset carve-outs at the transition rates of the GloBE Model Rules, Article 9.2) for the jurisdiction.
• A permanent Simplified ETR Safe Harbour replaces the simplified ETR test from 2027 (from 2026 in certain circumstances); groups can choose between the two during the overlap.
• Domestic implementation decides availability: check each jurisdiction's law (for example the EU Pillar Two Directive (EU) 2022/2523 as transposed, and local qualified domestic minimum top-up taxes).

9.2 Simplified ETR test, FY2026 (illustrative)

Simplified ETR = income tax expense in the qualified financial statements (current plus deferred, excluding taxes that are not covered taxes and uncertain tax positions) divided by profit before tax in the qualified CbC report.

Check: deferred 516 + 60 + 40 - 16 + 0 = 600, equal to the group deferred tax expense in the master file and in the income tax provision; 18,545 - 250 + 516 = 18,811 and 18,811 / 66,180 = 28.42%; 939 / 9,390 = 10.00%. The German uncertain tax position charge (250) is excluded from simplified covered taxes, as the safe harbour requires; the Netherlands FY2025 true-up stays in because it is part of the income tax expense in the qualified financial statements (check the current guidance on prior-year items).

9.3 Routine profits test for Vietnam, FY2026

Check: 86,400 x 9.4% = 8,121.6; 18,000 x 7.4% = 1,332.0; 8,121.6 + 1,332.0 = 9,453.6, rounded to 9,454; 9,454 - 9,390 = 64.

The group is in scope of Pillar Two for FY2026 because consolidated revenue was at least EUR 750m in at least two of the four preceding years (FY2023 EUR 755m, FY2024 EUR 760m and FY2025 EUR 820m all qualify); confirm with Pillar Two GloBE Readiness (finance/pillar-two-globe-readiness).

Example: Vietnam fails the simplified ETR test at 10.00% because of the 10% preferential rate, and fails the de minimis test (revenues of 131,640 are above EUR 10m), but passes the routine profits test by a margin of only EUR 64k, as it did in FY2025 (see Pillar Two GloBE Readiness, section 3.1). The top-up tax for Vietnam is therefore deemed zero under the Transitional CbCR Safe Harbour for FY2026, and the Vietnamese domestic minimum top-up tax should also be zero (check that Decree 236/2025/ND-CP applies the safe harbour to the domestic top-up tax). The margin is thin: a higher development fee, lower payroll or the lower FY2027 carve-out rates (9.2% and 7.2%) could turn the pass into a fail, so keep the full GloBE computation as a shadow calculation every year. A jurisdiction that fails all tests in one year cannot use the safe harbour in later years.

10. EU public country-by-country reporting

10.1 Scope

Directive (EU) 2021/2101 amended Directive 2013/34/EU (Articles 48a to 48j) to require public income tax information reports from groups and standalone undertakings whose consolidated revenue exceeded EUR 750m on the balance sheet date for each of the last two consecutive financial years, including non-EU groups with qualifying EU subsidiaries or branches. Member states apply it from the first financial year starting on or after 22 June 2024; for calendar-year groups the first report covers FY2025 and is due by the end of 2026. Check national transposition and the consolidated text.

Confirm whether the threshold test refers to the reporting year and the preceding year, or to the two years before the reporting year, in the national transposition; the example assumes the reporting year and the preceding year.

10.2 Example public report, FY2026

Revenues here follow the OECD Table 1 definition (unrelated plus related), which the Directive allows as an alternative presentation (check the consolidated text and the national law). Only EU member states are shown separately; no group entity is in a jurisdiction on Annex I or Annex II of the EU list at the reporting date (check the list in force), so all other jurisdictions are aggregated.

Check: rest of the world revenues 150,000 + 225,000 + 131,640 = 506,640; profit before tax 4,500 + 3,630 + 9,390 = 17,520; tax accrued 1,125 + 901 + 939 = 2,965; tax paid 1,020 + 840 + 850 = 2,710; accumulated earnings 14,000 + 9,500 + 21,000 = 44,500; employees 450 + 650 + 2,900 = 4,000.

Add a short narrative explaining material differences between tax accrued and tax paid, as the Directive expects (check Article 48c). Example: Tax paid is below tax accrued in every jurisdiction because final payments for FY2026 fall due in 2027.

10.3 Differences from the OECD CbC report

10.4 Publication plan

Consider aligning the narrative with the group's Tax Strategy Statement (finance/tax-strategy-statement), because readers will compare them.

11. Review, submission and retention log

Retain the workpaper, the XML, the receipts and the source data for at least the longest statutory retention period among the group's jurisdictions. Record any correction as a new version with the corrected message reference.

11.1 Lessons for next year

Example: The FY2026 preparation took three weeks longer than planned because tangible asset data for Vietnam were held only in local accounting software. Action ACT-001: map local fixed asset accounts to the group chart before the FY2027 close. Owner: [@group-controller]. Due: 2027-03-31.

12. Glossary and references

12.1 Glossary

12.2 References

Standard and licence note

Structure aligned with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Chapter V, Annex III, and based on the OECD/G20 Inclusive Framework Pillar Two Side-by-Side Package (January 2026, © OECD 2026, published under CC BY 4.0 as OECD material issued from 2024-07-01; earlier OECD material is used for structure and references only under the OECD terms and conditions). This is an adaptation in original wording; it does not represent the official views of the OECD or its Member countries. EU law (Directive (EU) 2021/2101, Council Directive (EU) 2016/881) is cited by article and summarised in original words (EUR-Lex reuse with acknowledgement); US Treas. Reg. 1.6038-4 is US public domain; the Vietnamese, German and UK rows are paraphrased from public law. Ostrander Group N.V., its subsidiaries and every figure are fictional. This template is original text written for this collection. Check the current official versions of the guidelines and each law before use. Template licence: MIT.