All OECD and G20 countries have committed to implementing country by country (CbC) reporting, as set out in the Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting”. Recognising the significant benefits that CbC reporting can offer a tax administration in undertaking ...
The OECD guidance addresses transitional filing options for MNE groups that operate in some jurisdictions (such as the US) that have not adopted country-by-country reporting effective for January 1st 2016; the application of country-by-country reporting to investment funds and partnerships; and how ...
On April 6, the OECD published additional guidance on the implementation of the country-by-country (CbC) reporting requirement proposed under Action 13 of its base erosion and profit shifting (BEPS) project. The guidance clarifies several interpretation issues related to the data to be included in...
- Annex III to Chapter V. Transfer Pricing Documentation – Country-by-Country Report - Annex IV to Chapter V. Country-by-Country Reporting Implementation Package - Annex to Chapter VI. Examples to Illustrate the Guidance on Intangibles - Annex to Chapter VIII. Examples to Illustrate the Guidance...
revised guidance on documentation (Chapter V)to include three-tiered approach to documentation (i.e.master file,local file and country-by-country reporting);∙ wholesale revision to the guidance on intangibles (Chapter VI);∙ inclusion of guidance on low value-adding intra-group services (LVAS...
转让定价同期资料和分国信息披露指引-OECDOnlineBookshop.PDF,转让定价同期资料和分国 信息披露指引 第13项行动计划 英文原作由 OECD 出版,标题如下: OECD/G20 Base Erosion and Profit Shifting Project. Guidance on Transfer Pricing Documentation and Country- by-Co
This2017editionoftheOECDTransferPricingGuidelinesincorporatesthesubstantialrevisionsmadein2016toreflecttheclarificationsandrevisionsagreedinthe2015BEPSReportsonActions8-10AligningTransferpricingOutcomeswithValueCreationandonAction13TransferPricingDocumentationandCountry-by-CountryReporting.Italsoincludestherevisedguidanceonsafeharbou...
Taxand UK discuses the new guidance in the Country-by-Country reporting programme. On 29 June 2016, the Organisation for Economic Co-operation and Development (OECD) announced additional guidance on the practical implementation of its Country-by-Country (CbC) Reporting programme, published in final...
2.3 Action13: Country-by-country reporting 2.3.1 implementation of CbC reporting filing obligation Action 13 established three tiered approach to TP documents: Master file - overview of an MNE's business and transfer pricing policies Local files - more detailed information on specific transactions wit...
Further administrative guidance The third set of administrative guidance has been released to further clarify the interpretation and operation of the model rules. Transitional country-by-country (CbC) reporting safe harbor The transitional CbC reporting safe harbor uses information taken from a business’...