Botswana still has no bilateral arrangements for exchanging multinational companies’ tax reports years after an international watchdog first raised the issue.
A newly reeased Country-by-Country Compilation of 2026 Peer Review by the Organisation for Economic Co-operation and Development’s (OECD) has revealed that Botswana has failed to establish key international arrangements required to exchange tax information on multinational companies. This has left the country facing a longstanding transparency gap under.
The findings which where prepared under the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) action 13, further reveal that Botswana has no bilateral relationships in place for exchanging country-by-country (CbC) reports; a critical mechanism designed to help tax authorities scrutinise the activities of multinational enterprises and assess whether profits are being reported and taxed appropriately across jurisdictions.
The shortcoming is not new. The OECD said the same recommendation was made during Botswana’s 2018/2019 peer review and remains unresolved in the 2026 assessment. It is understood that the continued absence of qualifying exchange arrangements raises questions about Botswana’s ability to participate effectively in the international sharing of multinational tax information even as it has introduced domestic legislation requiring country-by-country reporting. The OECD report acknowledges progress on domestic legislation. Botswana has introduced a filing requirement for country-by-country reports, removing an earlier recommendation that it enact legislation imposing the obligation. However, the international body says it has not yet been possible to review the legislation. The assessment of Botswana’s domestic legal and administrative framework will therefore be included in the next peer review.
The report’s overview lists several essential details as ‘TBC’ (to be confirmed), including the first reporting fiscal year, the consolidated group revenue threshold, the filing deadline, whether local filing is required, whether surrogate parent entity filing is permitted and when the domestic framework will first be reviewed. The country-by-country reporting is designed to give tax authorities a consolidated picture of large multinational groups’ operations across different jurisdictions.
The most persistent concern is Botswana’s failure to establish qualifying agreements for the automatic exchange of country-by-country reports with relevant jurisdictions. The OECD recommends that Botswana secure qualifying competent authority agreements with jurisdictions that belong to the Inclusive Framework, provided the necessary conditions are met and an international agreement allowing automatic exchange of tax information is already in effect.
These arrangements are intended to ensure that tax information can be exchanged securely and consistently with appropriate safeguards governing its use.
The report suggests that without such arrangements, Botswana lacks the established bilateral framework needed to receive and exchange these reports through the OECD’s country-by-country reporting mechanism.
The OECD’s recommendation has remained in place since the 2018/2019 review, making the issue a longstanding challenge rather than a newly identified weakness. The assessment also records improvements in two areas that were previously flagged by the OECD. Botswana has established processes or written procedures intended to ensure that information exchanges comply with the relevant terms of reference. The recommendation on those procedures has consequently been removed.
The country has also introduced controls to ensure that country-by-country reports are used appropriately. The OECD has therefore withdrawn its earlier recommendation on appropriate use. These developments indicate progress in preparing the administrative safeguards needed for international tax-information sharing. However, the absence of bilateral exchange relationships remains a central obstacle.
The distinction is important: having domestic filing requirements and safeguards for handling tax reports does not, on its own, establish the international agreements necessary to exchange those reports with other tax authorities. The findings come amid sustained international efforts to combat base erosion and profit shifting, practices through which multinational enterprises may exploit differences between national tax systems to shift profits away from jurisdictions where economic activity takes place.
The OECD/G20 BEPS Action 13 standard seeks to strengthen tax authorities’ access to information about the global allocation of income, taxes paid and indicators of economic activity within multinational groups.