OECD BEPS Action 13 Country-by-Country Reporting Training Course

Course overview

Country-by-Country (CbC) reporting creates a high-stakes data, governance and disclosure obligation for multinational enterprise groups. Tax teams must determine whether a group is in scope, identify the reporting entity and correct jurisdiction, reconcile financial and tax data across multiple systems, and file a consistent report within local deadlines. Errors in revenue, stated capital, employee counts, related-party revenue or tax paid can trigger enquiries, penalties, exchange-of-information issues and inconsistencies with the master file, local files and statutory accounts.

This course applies the OECD BEPS Action 13 framework to the full CbC reporting process. Participants work through the EUR 750 million consolidated-revenue threshold, constituent entity identification, surrogate parent and local filing rules, Table 1 data definitions, Table 2 business-activity classifications, and Table 3 explanatory narratives. They learn a repeatable method for building a jurisdictional data map, documenting source-system assumptions, validating figures, resolving data anomalies, preparing XML-ready outputs and managing notifications, filing calendars and post-filing enquiries.

Instruction combines technical briefings with worked multinational cases, spreadsheet-based data reconciliation, peer review and facilitator-led decision workshops. Participants complete a CbC reporting workpaper pack for a realistic group, including a scoping memo, reporting-entity decision tree, Table 1–3 draft, data-quality checks, filing calendar and governance checklist. The pack can be adapted as a practical starting point for their organisation's next reporting cycle.

The programme is designed for tax, transfer pricing, finance and compliance professionals who already work with multinational group data and need to own, review or challenge Action 13 reporting decisions. It is particularly valuable where reporting responsibilities are split between headquarters, local finance teams, shared-service centres and external advisers.

Course objectives

By the end of this course, participants will be able to:

• Determine CbC reporting scope using the EUR 750 million consolidated-revenue threshold and group consolidation analysis
• Identify the ultimate parent, surrogate parent, constituent entities and applicable local filing obligations
• Construct a jurisdiction-by-jurisdiction data map linking Table 1 fields to finance, tax and HR source systems
• Calculate and reconcile CbC revenue, profit, income tax, stated capital, accumulated earnings and employee measures
• Classify constituent-entity activities for Table 2 using OECD Action 13 business-activity categories
• Draft Table 3 explanations that document data sources, permanent-establishment treatment, currency conversion and material anomalies
• Validate a CbC report through completeness checks, cross-table reconciliations and XML submission controls
• Produce a documented CbC reporting governance pack with responsibilities, evidence retention and filing-calendar controls

Benefits of attending

Target competencies

Who should attend

• Transfer Pricing Managers — who coordinate Action 13 documentation and need defensible CbC reporting positions
• International Tax Managers — who assess parent, surrogate and local filing obligations across jurisdictions
• Group Tax Reporting Specialists — who compile tax data and reconcile it to consolidated financial information
• Tax Technology and Data Managers — who design source-data mappings, validation rules and XML reporting processes
• Group Financial Controllers — who supply jurisdictional financial data and need to understand CbC data definitions
• In-House Tax Compliance Managers — who oversee filing calendars, notifications, adviser inputs and audit responses

Requirements and prerequisites

Participants should have working knowledge of corporate income tax concepts, multinational group structures and consolidated financial statements. Familiarity with transfer pricing terminology, including related-party transactions, permanent establishments and the master file/local file distinction, is expected. Participants should be able to work confidently with spreadsheets, including filters, formulas and basic reconciliations, because exercises use Microsoft Excel workpapers. Prior preparation of a CbC report or XML file is not required, and no programming, tax-technology implementation or legal drafting experience is assumed. Participants without prior Action 13 exposure should review their organisation's latest transfer pricing documentation before attending.

Training methodology

The instructor uses OECD Action 13 rules alongside a single multinational case that develops across the five days. Participants make reporting-entity decisions, map data fields in Excel, reconcile Table 1 figures, classify activities for Table 2 and write Table 3 explanations for difficult fact patterns. Small groups review each other's workpapers against a structured control checklist, then defend key judgements in facilitator-led discussions. The final session converts the case output into an application plan, assigning practical actions for data owners, governance controls and the participant's next filing cycle.

Course outline

Day 1: Action 13 framework and reporting scope

• OECD BEPS Action 13 architecture and the purpose of Country-by-Country reporting
• Relationship between the master file, local file and CbC report
• EUR 750 million consolidated-revenue threshold testing
• Ultimate parent entity and multinational enterprise group identification
• Constituent entity definitions including permanent establishments
• Surrogate parent entity and local filing decision rules
• Jurisdictional notifications, exchange relationships and filing-calendar triggers

Workshop: Participants prepare a scoping memo and reporting-entity decision tree for a multinational group with subsidiaries and permanent establishments in several jurisdictions.

Day 2: Data architecture for Table 1

• Table 1 field definitions and jurisdiction aggregation principles
• Related-party revenue and unrelated-party revenue extraction methods
• Profit or loss before income tax source-data selection
• Income tax paid versus income tax accrued reconciliation
• Stated capital and accumulated earnings treatment
• Employee count methodologies and tangible-assets exclusions
• Currency conversion, materiality thresholds and data lineage documentation

Workshop: Participants build an Excel data map and reconcile a sample group's ledger, tax provision and HR extracts into a draft Table 1.

Day 3: Tables 2 and 3: entity detail and explanations

• Table 2 constituent-entity listing by tax jurisdiction
• Permanent-establishment reporting and jurisdiction assignment
• OECD business-activity category selection
• Dormant entities, holding companies and stateless entity treatment
• Table 3 narrative structure and explanatory conventions
• Documenting accounting-standard differences and fiscal-year mismatches
• Explaining acquisitions, restructurings, losses and exceptional tax outcomes

Workshop: Participants complete Tables 2 and 3 for the case group and produce written explanations for three material data anomalies.

Day 4: Validation, XML and reporting controls

• Cross-table validation between Tables 1, 2 and 3
• Reconciliation to consolidated accounts and tax provision data
• Data-quality rules for missing, negative and inconsistent values
• OECD CbC Reporting XML Schema structure and mandatory data elements
• XML generation, schema validation and submission-error diagnosis
• Version control, reviewer sign-off and evidence-retention protocols
• Managing amendments, corrections and tax-authority information requests

Workshop: Participants run a structured validation review on a flawed draft report, identify control failures and create a corrected filing-readiness checklist.

Day 5: Governance, risk interpretation and implementation

• CbC governance operating model and RACI design
• Annual reporting timetable and data-owner service levels
• Consistency testing against transfer pricing documentation
• Tax-authority risk indicators derived from CbC data
• Managing discrepancies between statutory accounts and CbC outcomes
• Internal review, audit committee reporting and external-adviser coordination
• Post-filing monitoring and continuous-improvement metrics

Workshop: Participants assemble their CbC reporting workpaper pack and present a 90-day implementation plan for improving their organisation's next filing cycle.

Tools & standards covered

OECD BEPS Action 13 Final Report, OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, OECD Country-by-Country Reporting XML Schema, Microsoft Excel

A typical training day

Live online deliveries follow the same structure in the East Africa Time zone, with shorter screen blocks and longer breaks.

What the fee includes

How you can take this course

Certification

Participants who complete the full five days receive the Skillset Development Certificate of Completion, stating the course title, course code, dates and delivery format — suitable for professional-development records and employer reimbursement.

Frequently asked questions