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