The Resource U.S. multinationals need to BEPS proof country-by-country reports

U.S. multinationals need to BEPS proof country-by-country reports

Label
U.S. multinationals need to BEPS proof country-by-country reports
Title
U.S. multinationals need to BEPS proof country-by-country reports
Creator
Subject
Language
eng
Summary
The U.S. is front and center in implementing the final report Action 13 of the international project to combat base erosion and profit shifting (BEPS). The crux of the post-BEPS reporting process is country-by-country reporting (CbCR), implemented through the October 2015 BEPS Action 13 final report. Each member country's tax administration and business taxpayers have essential roles to play in implementing the BEPS CbCR. Failure to comply with the reporting rules involves penalties ranging from thousands to hundreds of thousands of U.S. dollars in member countries that have implemented CbCR. Under the U.S. final CbCR regulations, 1.6038-4, 81 F.R. 42482, every ultimate parent entity of a U.S.-based multinational enterprise (MNE) with an annual revenue of $850 million - equivalent to 750 million euros threshold in BEPS Action 13 - or more in the immediately preceding reporting period is required to provide tax authorities with a breakdown of their allocation of profits by jurisdiction on a global basis, the amount of taxes paid on those profits, and certain other economic indicators. Applicable IRS Form 8975 and the associated schedule largely conform to the OECD's CbCR templates in the BEPS Action 13 final report. The U.S. regulations apply to fiscal years beginning on or after 30 June 2016, and the reporting deadline is the tax return due date for the given fiscal year, including extensions. The penalty rules under section 6038 generally apply with reasonable cause relief for failure to file. The IRS provides additional guidance on Form 8975 via Frequently Asked Questions on CbCR
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 26 (2017), no. 15 ; 3 p
http://library.link/vocab/creatorName
  • Feinschreiber, R
  • Li, W. (Weiye)
  • Chan, G
  • Abe, H
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • MNE
  • BEPS Project (OECD)
  • CbCR
  • transfer pricing
  • penalties
Label
U.S. multinationals need to BEPS proof country-by-country reports
Instantiates
Publication
Label
U.S. multinationals need to BEPS proof country-by-country reports
Publication

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