Economy

Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles

Published on October 05, 2015

Also available in: French

book

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. The revised standardised approach  will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. 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.

BEPS PACKAGE 2015

KEY MATERIAL


 WHAT'S NEW

12/05/2016 - A new boost to transparency in international tax matters: 6 new countries sign agreement enabling automatic sharing of country-by-country reporting
22/03/2016 - OECD releases standardised electronic format for the exchange of BEPS Country-by-Country Reports
27/01/2016 - A boost to transparency in international tax matters: 31 countries sign tax co-operation agreement to enable automatic sharing of country-by-country information

 

WEBCASTS

(Re)watch the discussions with senior members from the OECD's Centre for Tax Policy and Administration on the final outputs of the OECD/G20 Base Erosion and Project Shifting Project, including the next steps and the involvement of developing countries. 

  • Press conference for journalists with Pascal Saint-Amans, Director, CTPA.
  • BEPS webcast for tax experts with senior members of CTPA.

  

FURTHER INFORMATION

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.