The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. The BEPS Action 13 report (Transfer Pricing Documentation and Country-by-Country Reporting) provides a template for multinational enterprises (MNEs) to report annually and for each tax jurisdiction in which they do business the information set out therein. This report is called the Country-by-Country (CbC) Report.
The OECD regularly updates the list of jurisdictions implementing the BEPS Action 13 http://www.oecd.org/tax/beps/country-by-country-exchange-relationships.htm
As of October 2017, there are now already over 1000 bilateral exchange relationships activated with respect to more than 40 jurisdictions committed to exchanging CbC Reports, with first exchanges scheduled to take place in 2018.
Thus, the United Kingdom adopted OECD BEPS Action 13 on 26 February 2016. In particular, the United Kingdom will exchange CbC Reports with 46 jurisdictions such as Austria, Canada, China, Cyprus, Czech Republic, Estonia, Germany, Ireland, Latvia, Luxembourg, Malta, Singapore and other.
