OECD Administrative Guidance Addresses Year End Mismatches and Consolidated Revenue

The December 2023 OECD Administrative Guidance provides additional information on:

– the determination of consolidated revenue (for the 750 Million Euro revenue threshold) as different accounting standards can result in different definitions of ‘revenue’ for different MNE groups depending on the jurisdiction;

– MNE Groups where a UPE has a different fiscal year to some its subsidiaries (that are constituent entities);

– how MNEs should determine Adjusted Covered Taxes for a Fiscal Year if the taxable period for Constituent Entities in a jurisdiction is not the same as the Fiscal Year of the MNE Group.

Identifying Consolidated Revenue