On September 23, 2025 the OECD released a compilation of 2025 Peer Review Reports on Country-by-Country Reporting contained in the 2015 BEPS Action 13 Report. All members of the Inclusive Framework commit to implementing the BEPS Action 13 minimum standard and to participating in the peer review, on an equal footing. The peer review is a review of the legal and administrative framework put in place by a jurisdiction to implement the CbC reporting standard. In this article we focus on recommendations made to EU Member States, to the non-EU Members of the G7 and to certain Members of BRICS.
Outline of the key aspects assessed in the annual report
The peer review report released on September 23, 2025 contains the findings of the eighth annual peer review process undertaken by an Ad Hoc Joint Working Party 6 / Working Party 10 sub-group referred to as the “CbC Reporting Group”. This focuses on each jurisdiction’s domestic legal and administrative framework, its exchange of information network, and its measures to ensure the confidentiality and appropriate use of CbC reports.
The structure of each section relating to a specific reviewed jurisdiction is as follows:
- summary of filing requirements;
- a table summarising any recommendations issued;
- domestic legal and administrative framework;
- exchange of information; and
- appropriate use.
Jurisdictions which joined the Inclusive Framework after 1 October 2024 have not been reviewed as part of this annual peer review process. These jurisdictions will be included in the next peer review process.
This peer review evaluates an Inclusive Framework member’s implementation of the BEPS Action 13 minimum standard against an agreed set of criteria.1 These criteria are set out in terms of reference, which include each of the elements that a jurisdiction needs to demonstrate it has fulfilled in order to show proper implementation of the standard. These terms of reference are supplemented by additional questions for jurisdictions concerning measures they have implemented to ensure the appropriate use of CbC reporting information.
An agreed peer review methodology sets out the process for undertaking peer reviews of jurisdictions’ compliance with the BEPS Action 13 minimum standard on Country-by-Country (CbC) reporting. This methodology sets out the scope of the peer review, the information that will be used to conduct reviews, the timelines and procedures for a review, an outline of a peer review report, the process for discussion and approval of reviews, and the confidentiality of peer review documents. A new methodology published in 2020 replaces one agreed by the Inclusive Framework in 2017, which expired with the completion of the third annual peer review in September 2020. There has been no change to the terms of reference agreed by the Inclusive Framework in 2017.
The Global Forum has conducted preliminary expert assessments of confidentiality and data safeguards with respect to the standard on automatic exchange of information. Given its expertise in this area, the CbC Reporting Group has relied on the work and conclusions of the Global Forum. As it contains non-public information on jurisdictions’ internal systems and procedures, the outcomes of that work are not published and no further details of the review of confidentiality are provided in this compilation of peer review reports.
The terms of reference and methodology do not alter the BEPS Action 13 minimum standard. Any terms used in the terms of reference or methodology, and capitalised terms in this report, take their meaning from the language and context of the 2015 BEPS Action 13 Report (OECD, 2015[1])and the references therein.
Jurisdictions’ individual sections in this report generally reflect the status of implementation as of March 31, 2025 with the exception of information on the exchange of CbC reports which reflects the position as of December 31, 2024.
Recommendation made to EU Member States
Only 2 EU Member States (France & Romania) received recommendations from the Inclusive Framework.
France
Domestic legal and administrative framework
It is recommended that France ensure that local filing only occurs in the circumstances contained in the terms of reference. This recommendation remains in place since the 2017-2018 peer review.
France’s 2017-2018 peer review included a monitoring point with respect to the limitation of local filing to the instances of “Systemic Failure” as defined in paragraph 21 of the terms of reference. France confirms that its legislation implies that the obligations under the CbC MCAA are complied with (in particular the obligation for a prior consultation between Competent Authorities under Section 6 of the CbC MCAA) and will only apply local filing if there is a “Systemic Failure”. This monitoring point remains in place.
Romania
Domestic legal and administrative framework
It is recommended that Romania take steps to align its local filing implementation with that required by the Action 13 minimum standard. This recommendation remains in place since the 2017-2018 review.
Further remarks made regarding EU Member States include
France
France notified some late exchanges of CbC reports after the deadline, due to a technical issue. France has introduced measures to address the issue underlying this error. As France has taken steps to address this issue, no recommendation is made but this aspect will be monitored.
Hungary
Hungary notified some late exchanges of CbC reports after the deadline, due to error. As Hungary has taken steps to address this issue, no recommendation is made but this aspect will be monitored.
Romania
With respect to Romania it is noted that Romania is a non-reciprocal jurisdiction and, as such, will not receive CbC reports submitted to tax authorities in other jurisdictions. It is therefore not necessary for this peer review evaluation to reach any conclusions with respect to Romania’s compliance with the terms of reference on appropriate use.
For information, Romania has provided details of the controls it has in place to ensure the appropriate use of CbC reports, which comply with published Guidance on the Appropriate Use of Information Contained in CbC Reports.
Recommendation made to non-EU Members of the G7
Canada
No recommendations made.
Japan
No recommendations made.
United Kingdom
No recommendations made.
The United States
The domestic legal and administrative framework
It is recommended that the United States ensure that the definitions of “revenue” for the purposes of applying the threshold and for completing Table 1 are consistent with the definition in the Action 13 minimum standard, as further clarified by OECD guidance. This recommendation remains in place since the 2017-2018 peer review.
The United States operates a modified filing requirement for MNEs which qualify as state security contractors. In light of the United States’ explanations and the limited number of MNE Groups that are likely to qualify for the specified national security contractor status, no recommendation is made, but use of modified reporting will be monitored. This monitoring point remains in place since the 2018/19 peer review.
The exchange of information framework
It is recommended that the United States’ competent authority should continue to work actively towards signing bilateral competent authority arrangements with jurisdictions of the Inclusive Framework that meet the confidentiality, consistency and appropriate use conditions, and with which the United States has an agreement in effect that allows for the automatic exchange of information. This recommendation remains in place since the 2017-2018 peer review.
Recommendation made to important members of BRICS
Brazil
No recommendations made.
The Russian Federation
The domestic legal and administrative framework
It is recommended that Russia amend its legislation or otherwise takes steps to ensure that local filing is only required in the circumstances contained in the terms of reference. This recommendation remains in place since the 2017-2018 peer review.
It is recommended that Russia amend its legislation or otherwise take steps to ensure that enforcement provisions and monitoring relating to CbC reporting’s effective implementation are provided for as contained in the terms of reference as from the first reporting period. This recommendation remains in place since the 2017-2018 peer review.
India
The domestic legal and administrative framework
It is recommended that India amend or otherwise clarify that the annual consolidated group revenue threshold calculation rule applies in a manner consistent with the OECD guidance on currency fluctuations in respect of an MNE Group whose Ultimate Parent Entity is located in a jurisdiction other than India. This recommendation remains in place since the 2017-2018 peer review.
It is recommended that India amend its legislation or otherwise takes steps to ensure that local filing is only required in the circumstances contained in the terms of reference. This recommendation remains in place since the 2017-2018 peer review.
The People’s Republic of China
The domestic legal and administrative framework
It is recommended that China clarify the exact scope, conditions and legal basis under the minimum standard and/or the exchange of information framework for the filing exemption in relation to information relating to National Security. This recommendation remains in place since the 2017-2018 peer review.
It is recommended that China amend its legislation or otherwise takes steps to ensure that local filing is only required in the circumstances contained in the terms of reference. This recommendation remains in place since the 2017-2018 peer review.
South Africa
No recommendations made.
United Arab Emirates
No recommendations made.
Further remarks made regarding abovementioned BRICS members
United Arab Emirates
UAE is a non-reciprocal jurisdiction and, as such, will not receive CbC reports submitted to tax authorities in other jurisdictions, and will not apply local filing. It is therefore not necessary for this peer review evaluation to reach any conclusions with respect to compliance with the terms of reference on appropriate use.
The full compilation of 2025 Peer Review Reports on Country-by-Country Reporting as release by the OECD on September 23, 2025 can be found here on the website of the OECD.
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