Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
This document contains revised standards for transfer pricing documentation and a
template for country-by-country reporting of revenues, profits, taxes paid and certain
measures of economic activity. These new reporting provisions, and the transparency
they will encourage, will contribute to the objective of understanding, controlling,
and tackling BEPS behaviours. Countries participating in the BEPS project will carefully
review the implementation of these new standards and will reassess no later than the
end of 2020 whether modifications should be made to require reporting of additional
or different data. Effective implementation of the new reporting standards and reporting
rules will be essential. Additional work will be undertaken to identify the most appropriate
means of filing the required information with and disseminating it to tax administrations.
27/01/2016: 31 countries sign tax co-operation agreement to enable automatic sharing of country-by-country information
As part of continuing efforts to boost transparency by multinational enterprises (MNEs), 31 countries signed today the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports. The signing ceremony marks an important milestone towards implementation of the OECD/G20 BEPS Project and a significant increase in cross-border cooperation on tax matters.
The MCAA will enable consistent and swift implementation of new transfer pricing reporting standards developed under Action 13 of the BEPS Action Plan.
16/11/2015 - G20 leaders endorse OECD measures to crack down on tax loopholes, reaffirm its role in ensuring strong, sustainable and inclusive growth
The leaders of the world’s 20 largest economies today endorsed overhauled global standards to crack down on tax avoidance and recognised the important contribution made by the OECD to help the Turkish presidency in achieving the goal of more inclusive growth.
08/06/2015: OECD releases Implementation Package for BEPS country-by-country reporting
Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project.
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.
06/02/2015: First steps towards implementation of OECD/G20 efforts against tax avoidance by multinationals
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 750 million in their countries of residence starting in 2016. Tax administrations will begin exchanging the first country-by-country reports in 2017 . Countries have emphasised the need to protect tax information confidentiality.
The guidance confirms that the primary method for sharing such reports between tax administrations is through automatic exchange of information, pursuant to government-to-government mechanisms such as bilateral tax treaties, the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, or Tax Information Exchange Agreements (TIEAS). In certain exceptional cases, secondary methods, including local filing can be used.