Today, in response to Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan, the OECD released guidance on implementing country-by-country reporting.  The guidance consists of (1) model legislation which could be used by countries to require the ultimate parent entity of a multinational group to file the country-by-country report in its jurisdiction of residence, including backup filing requirements, and (2) three model competent authority agreements that could be used to facilitate implementation of the exchange of country-by-country reports.  Country-by-country reporting requirements are intended to enhance transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks.