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 ...
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 ...
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 ...
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...
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...
The substantial revisions introduced by the 2015 BEPS Reports on Actions 8-10 (aligning transfer pricing outcomes with value creation) and Action 13 (transfer pricing documentation and country-by-country reporting); The revisions to Chapter IX of the TP Guidelines to conform the guidance on business...
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...
(particularly in the early years of implementation and for low-risk jurisdictions), the IF has designed the following measures: Transitional country-by-country reporting (CbCR) safe harbour This safe harbour is a temporary measure and would effectively exclude from the scope of the GloBE rules a ...
This2017editionoftheOECDTransferPricingGuidelinesincorporatesthesubstantialrevisionsmadein2016toreflecttheclarificationsandrevisionsagreedinthe2015BEPSReportsonActions8-10AligningTransferpricingOutcomeswithValueCreationandonAction13TransferPricingDocumentationandCountry-by-CountryReporting.Italsoincludestherevisedguidanceonsafeharbou...
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’...