TPG2022 Chapter V paragraph 5.55

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It is considered that no exemptions from filing the Country-by- Country Report should be adopted apart from the exemptions outlined in this section. In particular, no special industry exemptions should be provided, no general exemption for investment funds should be provided, and no exemption for non-corporate entities or non-public corporate entities should be provided. Notwithstanding this conclusion, MNE groups with income derived from international transportation or transportation in inland waterways that is covered by treaty provisions that are specific to such income and under which the taxing rights on such income are allocated exclusively to one jurisdiction, should include the information required by the Country-by-Country Report template with respect to such income only against the name of the jurisdiction to which the relevant treaty provisions allocate these taxing rights.

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