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

CbCR workpaper: EUR 750m test, filing and notification plan, Tables 1-3, reconciliation, risk indicators, Pillar Two transitional safe harbour, EU public CbCR

財務・投資・会計フルBEPS Action 13 (OECD TPG 2022 Chapter V Annex III); OECD Pillar Two Side-by-Side Package 2026; Directive (EU) 2021/2101countryreportworkpaper

使い方: Use it when your group (consolidated revenue of EUR 750m or more in the preceding year) prepares its country-by-country report. Fill the threshold test and the filing and notification calendar first, then Table 1 from consolidation packages and reconcile it. The main pitfall is reporting deferred tax in income tax accrued or missing a local notification deadline.

プレビュー

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.

Document control

FieldValue
Document ID[CBCR-FY2026]
Version[1.0]
Status[Draft / In review / Approved / Filed / Superseded]
MNE group[Group name] Example: Ostrander Group
Reporting entity and role[Legal name, jurisdiction; ultimate parent / surrogate parent / local filing] Example: Ostrander Group N.V., Netherlands, ultimate parent
Reporting fiscal year[YYYY-MM-DD to YYYY-MM-DD] Example: 2026-01-01 to 2026-12-31
Reporting currency and units[EUR thousand]
Data source basis[Consolidation reporting packages / statutory accounts / management accounts]
Owner[@head-of-tax]
Prepared by[@tax-reporting-manager]
Approvers/reviewers[@cfo], [@group-controller], [@tp-manager]
Last updatedYYYY-MM-DD
Classification[Confidential: tax data]
Filing reference[XML MessageRefId and submission receipt]

Approvals

RoleNameDecisionDate
Head of Tax[@name][Approve / Return]YYYY-MM-DD
Group Controller (data and reconciliation)[@name][Confirm / Return]YYYY-MM-DD
Chief Financial Officer[@name][Approve filing]YYYY-MM-DD

Revision history

VersionDateAuthorChange
0.1YYYY-MM-DD[@author]Data request issued and scope test
0.9YYYY-MM-DD[@author]Tables complete, reconciliation reviewed
1.0YYYY-MM-DD[@author]Approved for filing

Contents

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.

TestValueResult
Consolidated revenue, preceding fiscal year FY2025 (Example)EUR 820,000kAt or above EUR 750m
Consolidated revenue, reporting year FY2026 (for information, decides FY2027) (Example)EUR 900,000kAt or above EUR 750m
Local thresholds that differ (Example)US threshold not relevant (group not US-parented); Vietnam EUR 750m equivalent metNot applicable
Conclusion (Example)CbC report required for FY2026, filed by the UPE in the Netherlands

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

ItemValue
Ultimate parent entity (UPE)[Name, jurisdiction] Example: Ostrander Group N.V., Netherlands
Does the UPE jurisdiction require CbC filing?[Yes / No] Example: Yes (Corporate Income Tax Act 1969 (Wet Vpb), articles 29b to 29h, implementing DAC4 (check))
Exchange relationships with each jurisdiction of operation[Qualifying competent authority agreement in effect: Yes / No per jurisdiction]
Surrogate parent entity, if any[Name, jurisdiction, reason] Example: None
Local filing triggered anywhere?[Yes / No, jurisdiction, reason] Example: No

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

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

JurisdictionLegal basis (as of 2026-10)ObligationDeadlineOwner
NetherlandsCorporate Income Tax Act 1969 (Wet Vpb), articles 29b to 29h, implementing DAC4 (check)UPE files the CbC report with the Dutch tax administration; Dutch entities notify which entity reports (check)Report within 12 months of fiscal year end[@head-of-tax]
GermanySection 138a AO (check the current text)German entity of a foreign-parented group states in its tax return that it belongs to a group and names the reporting entityWith the tax return (check)[@de-finance-lead]
United KingdomUK country-by-country reporting regulations (SI 2016/237)UK entities notify HMRC which entity files, unless exemptNotification by the end of the reporting period (check)[@uk-finance-lead]
VietnamDecree 255/2026/ND-CPVietnamese entity notifies the tax authority on Form 01/TB-BCLN, generally once by the end of the UPE's fiscal year, and updates within 90 days of a changeAs stated; confirm in the decree text[@vn-finance-manager]
United StatesTreas. Reg. 1.6038-4; Form 8975US-parented groups with USD 850m or more file with the UPE's income tax return; foreign-parented groups generally do not file in the US if the parent jurisdiction exchangesWith the return, including extensions[@us-finance-lead]
European UnionCouncil Directive (EU) 2016/881 (DAC4)Member states require filing and exchange in line with Action 13, including secondary filing rules12 months after fiscal year end[@head-of-tax]
[Other][Law][Obligation][Deadline][@owner]

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

ItemChoiceReason
Data source (Example)Consolidation reporting packages (IFRS) before eliminationsSame data as the audited group accounts; available for all entities on the group close timetable
Currency translation (Example)Average rate for the year for income items; closing rate for balances (stated capital, accumulated earnings, tangible assets)Consistent with the group accounts
Aggregation (Example)By tax jurisdiction of residence; entities with no tax residence reported as statelessOECD Annex III instructions
Employees (Example)Full-time equivalents at year endConsistent with the master file; independent contractors counted only if they take part in ordinary operating activities (check guidance)
Intra-group dividends (Example)Excluded from revenues and profit before tax in line with OECD implementation guidanceAvoids double counting

3.2 Data request

Request IDData itemSourceEntity ownerDue
DR-001 (Example)Revenue split: unrelated and related partiesReporting package, intercompany moduleEntity controllersYear end plus 6 weeks
DR-002 (Example)Profit before taxReporting packageEntity controllersYear end plus 6 weeks
DR-003 (Example)Current tax accrued and tax paid in cashTax provision and payment recordsTax teamYear end plus 8 weeks
DR-004 (Example)Stated capital and accumulated earningsStatutory balance sheetEntity controllersYear end plus 8 weeks
DR-005 (Example)FTE at year endHR systemHRYear end plus 4 weeks
DR-006 (Example)Tangible assets other than cashFixed asset registerEntity controllersYear end plus 6 weeks

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)

ColumnSummary of what to include
Revenues, unrelated partyRevenue from independent parties, including sales, services, royalties, interest and other income; exclude intra-group dividends
Revenues, related partyRevenue from other constituent entities of the group
Profit or loss before income taxSum for all constituent entities in the jurisdiction, including extraordinary items
Income tax paid (cash basis)Cash taxes paid in the year to any jurisdiction, including withholding tax suffered
Income tax accrued (current year)Current tax expense on the year's taxable profits; exclude deferred tax and provisions for uncertain positions
Stated capitalStated capital of the constituent entities; for permanent establishments, as reported by the head office
Accumulated earningsTotal accumulated earnings at year end
Number of employeesFTE or headcount at year end, on a consistent basis
Tangible assets other than cashNet book value; exclude cash, cash equivalents, intangibles and financial assets

4.2 Table 1 data

JurisdictionRevenues unrelatedRevenues relatedRevenues totalProfit before taxTax paidTax accruedStated capitalAccumulated earningsEmployeesTangible assets
NL (Example)300,000518,120818,12066,18017,10018,545120,000310,0001,40052,000
DE (Example)210,0000210,0006,3001,7501,89010,00018,0006009,000
GB (Example)150,0000150,0004,5001,0201,1258,00014,0004506,500
US (Example)225,0000225,0003,63084090115,0009,5006509,500
VN (Example)15,000116,640131,6409,39085093920,00021,0002,90018,000
Total900,000634,7601,534,76090,00021,56023,400173,000372,5006,00095,000

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

JurisdictionComponentAmount (EUR thousand)Source
NL (Example)Sales of subscriptions and goods to OST-DE175,000Intercompany ledger
NL (Example)Sales of subscriptions and goods to OST-UK125,000Intercompany ledger
NL (Example)Sales of subscriptions and goods to OST-US190,000Intercompany ledger
NL (Example)Sales of goods to OST-VN12,000Intercompany ledger
NL (Example)Group service charges to OST-DE, OST-UK, OST-US, OST-VN (4,000 + 3,000 + 4,500 + 1,500)13,000Allocation file
NL (Example)Interest on loan FIN-001 to OST-US3,120Treasury system
VN (Example)Development service fee from OST-NL (CT-001)116,640Local file 3.1
Total634,760

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).

JurisdictionEntity ID and nameTax residence if differentMain activities (Example)
NLOST-NL Ostrander Group N.V.Research and development; holding or managing IP; purchasing or procurement; sales, marketing or distribution; administrative, management or support services; internal group finance; holding shares or other equity instruments
DEOST-DE Ostrander Deutschland GmbHSales, marketing or distribution; services to unrelated parties
GBOST-UK Ostrander UK LtdSales, marketing or distribution; services to unrelated parties
USOST-US Ostrander IncSales, marketing or distribution; services to unrelated parties
VNOST-VN Ostrander Vietnam Co., LtdResearch and development; sales, marketing or distribution

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

LineCbC Table 1 (EUR thousand)Eliminations and adjustmentsConsolidated accountsDifference
Revenues (Example)1,534,760(634,760) intra-group revenues900,0000
Profit before tax (Example)90,0000 (unrealised intra-group profit in closing inventory immaterial)90,0000
Current tax expense (Example)23,4000 net: German uncertain tax position charge 250, Netherlands FY2025 return-to-provision credit (250)23,4000
Employees (FTE) (Example)6,00006,0000

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

Check IDCheckResult (Example)
QC-001Every entity in Table 2 belongs to a jurisdiction in Table 1Pass
QC-002Related revenues equal the intercompany ledger after matchingPass (difference EUR 0k)
QC-003Tax accrued excludes deferred tax and uncertain tax provisionsPass
QC-004Employees agree with HR data and the master filePass (6,000)
QC-005Tangible assets exclude cash, intangibles and financial assets; state in Table 3 whether right-of-use assets are includedPass (right-of-use assets included, stated in Table 3)
QC-006XML passes schema validation in the filing portal[Pass / Fail, error code]
QC-007Signs: losses shown as negative numbersPass (no losses)

8.2 Risk indicators by jurisdiction

JurisdictionProfit before tax per employeeRevenue per employeeTax accrued / profit before taxRelated revenues / total revenuesTax paid / tax accrued
NL (Example)47.27584.428.0%63.3%92.2%
DE (Example)10.50350.030.0%0.0%92.6%
GB (Example)10.00333.325.0%0.0%90.7%
US (Example)5.58346.224.8%0.0%93.2%
VN (Example)3.2445.410.0%88.6%90.5%
Group (Example)15.00150.0 (external revenues)26.0%41.4%92.1%

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.

JurisdictionCurrent tax accruedPrior-year adjustment in the accountsDeferred tax expense (credit)Simplified covered taxesProfit before taxSimplified ETRTransition rateResult
NL (Example)18,545(250)51618,81166,18028.42%17%Pass
DE (Example)1,8900601,9506,30030.95%17%Pass
GB (Example)1,1250401,1654,50025.89%17%Pass
US (Example)9010(16)8853,63024.38%17%Pass
VN (Example)939009399,39010.00%17%Fail: test routine profits

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

ItemAmount (EUR thousand)
Eligible payroll costs (Example)86,400
Payroll carve-out at 9.4% (Example)8,122
Eligible tangible assets, average of opening and closing carrying value (opening and closing both about 18,000) (Example)18,000
Tangible asset carve-out at 7.4% (Example)1,332
Substance-based income exclusion (SBIE) (Example)9,454
Profit before tax in the qualified CbC report (Example)9,390
Margin (SBIE less profit before tax) (Example)64
Result (Example)Pass: profit before tax does not exceed the SBIE

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.

Test (Example)ValueResult
Consolidated revenue above EUR 750m in FY2025 and FY2026 (the two years ending with the reporting year)?EUR 820,000k and EUR 900,000kYes
Was FY2025 also reportable (FY2024 and FY2025 both above the threshold)?EUR 760,000k and EUR 820,000kYes: first report for FY2025 due by 2026-12-31
ConclusionIn scope; OST-NL publishes the FY2026 report by 2027-12-31

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.

JurisdictionActivitiesEmployees (FTE)RevenuesProfit before taxIncome tax accruedIncome tax paidAccumulated earnings
Netherlands (Example)Group management, platform ownership, sales1,400818,12066,18018,54517,100310,000
Germany (Example)Distribution600210,0006,3001,8901,75018,000
Rest of the world (UK, US, Vietnam) (Example)Distribution, software development4,000506,64017,5202,9652,71044,500
Total6,0001,534,76090,00023,40021,560372,500

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

TopicOECD CbC report (confidential)EU public report (Article 48c; check the consolidated text)
AudienceTax authorities onlyPublic, on the company website and in the business register
Jurisdiction breakdownEvery jurisdictionEach EU member state separately; each jurisdiction on the EU list of non-cooperative jurisdictions (Annex I) and, under conditions, Annex II separately; all other jurisdictions aggregated as "rest of the world"
Data itemsTable 1 to 3Name of the parent, financial year, currency, list of EU and listed-jurisdiction subsidiaries, description of activities, employees, revenues, profit or loss before tax, income tax accrued, income tax paid, accumulated earnings
Items not requiredNot applicableStated capital and tangible assets are not required
DeferralNot applicableCommercially sensitive items may be omitted temporarily (up to five years, with disclosure of the omission), never for listed non-cooperative jurisdictions
Deadline12 months after year endPublished within 12 months of the balance sheet date and kept accessible for at least five years
FormatOECD XML schemaCommon template and machine-readable electronic formats set by Commission Implementing Regulation (EU) 2024/2952 (check the current act)
AssuranceNoneStatutory auditor states whether the report was required and published (check national law)

10.4 Publication plan

StepOwnerDate
Map entities to EU, Annex I, Annex II and rest-of-world groups[@tax-reporting-manager]YYYY-MM-DD
Draft narrative and data from Table 1[@tax-reporting-manager]YYYY-MM-DD
Safeguard clause decision and documentation[@head-of-tax], [@legal]YYYY-MM-DD
Board approval and publication on the website[@company-secretary]YYYY-MM-DD
Filing in the business register[@company-secretary]YYYY-MM-DD

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

StepOwnerDateEvidence
Data received from all entities[@tax-reporting-manager]YYYY-MM-DD[Data request tracker]
Reconciliation reviewed (section 7)[@group-controller]YYYY-MM-DD[Reconciliation file]
Consistency with master and local files[@tp-manager]YYYY-MM-DD[Review notes]
Approval to file[@cfo]YYYY-MM-DD[Approval record]
XML generated and validated[@tax-reporting-manager]YYYY-MM-DD[Validation report]
Submitted to [tax authority][@head-of-tax]YYYY-MM-DD[Receipt, MessageRefId]
Status message received[@head-of-tax]YYYY-MM-DD[Accepted / Errors to correct]
Local notifications filed[@local-finance-leads]YYYY-MM-DD[Receipts]

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

TermMeaning
BEPSBase erosion and profit shifting, the OECD/G20 project that set the CbC minimum standard (Action 13)
CbC reportCountry-by-country report under BEPS Action 13
Constituent entityA business unit or permanent establishment of the MNE group included in the report
DAC4Council Directive (EU) 2016/881 on the automatic exchange of CbC reports
GloBEGlobal Anti-Base Erosion rules (Pillar Two)
Qualified CbC reportA CbC report prepared from qualified financial statements, as needed for the Transitional CbCR Safe Harbour
Surrogate parent entityA group entity appointed to file in place of the ultimate parent
Transition rateThe minimum simplified ETR for the safe harbour in a given year
UPEUltimate parent entity

12.2 References

ReferenceVersion or date checkedUse
OECD Transfer Pricing Guidelines 2022, Chapter V, Annex III2022 edition, checked 2026-10-25Table structure and column summary
OECD/G20 Inclusive Framework, Pillar Two Side-by-Side PackageJanuary 2026 (approved 2026-01-05)Extension of the Transitional CbCR Safe Harbour; transition rates
Directive (EU) 2021/2101 amending Directive 2013/34/EUAdopted 24 November 2021; applies from financial years starting on or after 22 June 2024EU public CbCR
Council Directive (EU) 2016/881 (DAC4)Checked 2026-10-25EU filing and exchange
US Treas. Reg. 1.6038-4eCFR text checked 2026-10-25USD 850m threshold and Form 8975 timing
Vietnam Decree 255/2026/ND-CPEffective 2026-07-01EUR 750m equivalent threshold; Form 01/TB-BCLN
Germany section 138a AO; UK SI 2016/237Not re-checked; confirmFiling and notification rows

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.

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