In September 2013, the Organization for Economic Co-operation and Development (OECD) and G20 countries, working together on an equal footing, adopted an ambitious and comprehensive 15-point Action Plan to address BEPS. The Action Plan aims to ensure that profits are taxed where economic activities generating the profits are performed and where value is created. The Action Plan is based on three Pillars; (i) coherence of corporate tax at the international level; (ii) substance or value creation; and (iii) cooperation and transparency, coupled with certainty and predictability. 

Actions 11 through 14 call for greater Transparency, coupled with certainty and predictability to curb BEPS. Specifically, BEPS Action 13 requires the OECD to: 

– "develop rules regarding transfer pricing documentation to enhance transparency for tax administrations, taking into consideration the compliance costs for business.  

– The rules to be developed will include a requirement that MNEs provide all governments with needed information on their global allocation of the income, economic activity and taxes paid among countries according to a common template."

In response to this requirement, jurisdictions participating in the BEPS Project agreed on revised standards for transfer pricing documentation and a template for country-by-country reporting of income, taxes paid and certain measures of economic activity. On 16 September 2014, the OECD published the "Guidance on Transfer Pricing Documentation and Country-by-Country Reporting" that provided template for country-by-country reporting. 

The work on the comprehensive Action Plan on BEPS was concluded in October 2015 and a package of 15 reports delivered, culminating in new or reinforced international standards as well as producing concrete measures to help countries tackle BEPS. One of these measures is the Country-by-Country reporting under Action 13 of the BEPS Project, which is a minimum standard under the BEPS outcomes.

Nigeria is a member of the Inclusive Framework, a group of jurisdictions, committed to the implementation of the minimum standards of the BEPS related measures. Towards this end, Nigeria signed the Multilateral Competent Authority Agreement on Country-by-Country Reporting (CbC MCAA) in January 2016 and has produced the Income Tax (Country-by-Country Reporting) Regulations 2018 ("CbC Regulations") for the implementation of the Country-by-Country Reporting in Nigeria. Relevant documents required for the implementation of CbC Reporting in Nigeria can be found on this page.







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