Guidance on transfer pricing documentation and country by country reporting

BEPS Action 13: Transfer Pricing Documentation & Country-by-Country Reporting

guidance on transfer pricing documentation and country by country reporting

Sep 16, This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues.

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TD — Country-by-Country Reporting. Revenue Procedure Guidance for ultimate parent entities of U. This revenue procedure discusses the timing and manner of these early filings. Model arrangement for the U. It also explains the information required to be included in each reported data element. Form , Country-by-Country Report.

The updated Guidance also includes a summary table of the existing interpretative guidance on cases of mergers, demergers and acquisitions. For example, in September the OECD issued two handbooks one on the effective implementation of CbC reporting and another on effective tax risk assessment , 9 and a report on the appropriate use of information contained in CbC Reports. However, the final report did not address whether the same approach should apply to the column on Profit loss before Income Tax. As the Action 13 final report did not provide specific instructions on this issue and jurisdictions may have taken different approaches, the Guidance takes a flexible approach allowing jurisdictions to maintain their own approach. The Guidance clarifies that amounts in Table 1 should be reported in full whole units, and therefore any rounding to shorten amounts is not permitted. By way of example, the guidance explains that an amount of should not be reported in thousands, and accordingly shortened, for example, to

We consider here action 13 of the OECD's BEPS Action Plan, aimed at re-examining transfer pricing documentation requirements — and in particular providing for more information from taxpayers. Such information will offer useful indicators for risk assessment and allow tax administrations to better focus their limited resources. Our Tax Insight of 7 June notes that it refers to a Regulation addressing these new documentation requirements to reflect Action 13 being published in due course. Taxpayers who ended their fiscal year on 31 December would then be required to prepare transfer pricing documentation by the end of September As previously, the complete set of guidance related to CbC reporting issued so far is presented in the released document. Also released is a compilation of the approaches adopted by member jurisdictions of the Inclusive Framework with respect to issues where the guidance allows for alternative approaches.

Also available in: German , French , Korean , Chinese. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer pricing reporting standards developed under Action 13 of the BEPS Action Plan, ensuring that tax administrations obtain a complete understanding of the way multinational enterprises MNEs structure their operations, while also ensuring that the confidentiality of such information is safeguarded. A key objective of the BEPS project is to increase transparency through improved transfer pricing documentation standards - including through the use of a country-by-country reporting template that requires multinationals to provide tax administrations with information on revenues, profits, taxes accrued and paid, along with some activity indicators. The new guidance presented to the G20 requires country-by-country reporting by multinationals with a turnover above EUR million in their countries of residence starting in Tax administrations will begin exchanging the first country-by-country reports in Countries have emphasised the need to protect tax information confidentiality.



Country-by-Country Reporting Guidance

The essence of the initiative is to develop coordinated actions that curb the ability of multinational enterprises MNEs to shift income arbitrarily to tax jurisdictions offering low tax rates. Among the items identified, Action 13 calls for a re-examination of transfer pricing documentation requirements in order to enhance transparency among tax administrations regarding individual taxpayers.

Also available in: German , Spanish , French. Base Erosion and Profit Shifting BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports.

This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues, profits, taxe.
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