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HMRC internal manual

International Exchange of Information Manual

Country-by-Country reporting: OECD guidance

CbC reporting is being implemented across the world and to ensure consistency the first place to seek guidance is the OECD report which contains a lot of detailed guidance about completing a CbC report. 

This guidance is also being updated regularly and the UK is involved in discussions at the OECD to arrive at agreed answers to issues raised. The latest guidance published is available at:

In general when completing the CbC report, the data should be drawn from consistent sources each year.  HMRC does not specify which data sources should be used but these can include consolidation reporting packages, separate entity statutory financial statements, regulatory financial statements or internal management accounts. 

In addition to drawing on the MNE group’s financial data, the OECD have provided specific guidance to assist with completing the CbC report.  For example, clarifying the definition of revenue. More information can be found at Annex III of the Action 13 report.   

If you consider that an entry on the CbC report requires further clarification, Table 3 of the CbC report should be used to provide any additional narrative.

This guidance will help customers complete a CbC report, but where a customer has an issue that is not addressed by this or the OECD’s guidance, they should contact their Customer Compliance Manager (CCM). If the customer has no CCM, email queries should be sent to  Please include “CbCR” within the subject line.