OECD CbC reporting review records wider exchange coverage

An implementation review, not a new reporting mandate

The underlying BEPS Action 13 report, Transfer Pricing Documentation and Country-by-Country Reporting, provides the reporting template and model implementation package. Its purpose is to help tax authorities assess transfer-pricing and other base-erosion risks through tax-authority exchanges, with confidentiality and appropriate-use safeguards. The new peer review assesses implementation; it does not amend the standard or itself impose new filing duties.^[1][3]

More exchange arrangements, continuing domestic gaps

The 2025 compilation reported 101 jurisdictions with multilateral or bilateral competent authority agreements and sufficient assurance on appropriate-use measures for 89. It recommended that 22 jurisdictions establish or finalise domestic legal or administrative frameworks, while 27 received recommendations on specific features. Its Viet Nam chapter retained two exchange-framework recommendations alongside a separate local-filing recommendation.^[2]

The 2026 figures are 110 jurisdictions with agreements and 94 with appropriate-use assurance. General domestic-framework recommendations fall to 19 jurisdictions and specific recommendations to 25. These separate categories are not a unique total of deficient jurisdictions, nor do agreement counts establish that every bilateral exchange route operates.^[1]

Viet Nam illustrates why separate assessments matter

The new report removes both exchange recommendations for Viet Nam, recording activated relationships and procedures now in place. The local-filing recommendation remains. Viet Nam is non-reciprocal and does not receive other authorities’ reports: the OECD consequently makes no appropriate-use assessment, although it records information about controls. Exchange progress therefore does not amount to a clean assessment across all areas.^[1][2]

For group tax teams, our practical reading is to check the particular filing route and exchange relationship, not assume blanket filing relief. As the 2025 report explains, ultimate-parent filing generally feeds automatic tax-authority exchange under an international agreement plus a qualifying competent authority agreement. Domestic requirements and that exchange network need separate attention.^[2][3]

Read the findings at their stated cut-off dates

The 2026 country sections generally reflect implementation at 31 March 2026 and exchange information at 31 December 2025, not publication-day positions. Russia’s 2021 and Belarus’s 2022 reports are included for information, not as new assessments. Later domestic and exchange changes require their own current-source checks.^[1]