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The Resource Transfer pricing documentation and country-by-country reporting, Action 13 - 2015 final report

Transfer pricing documentation and country-by-country reporting, Action 13 - 2015 final report

Label
Transfer pricing documentation and country-by-country reporting, Action 13 - 2015 final report
Title
Transfer pricing documentation and country-by-country reporting, Action 13 - 2015 final report
Subject
Language
eng
Summary
This report contains revised standards for transfer pricing documentation and a template for Country-by-Country Reporting of income, taxes paid and certain measures of economic activity. Action 13 of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan, OECD, 2013) requires the development of "rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into consideration the compliance costs for business. The rules to be developed will include a requirement that MNEs provide all relevant governments with needed information on their global allocation of the income, economic activity and taxes paid among countries according to a common template". In response to this requirement, a three-tiered standardised approach to transfer pricing documentation has been developed. First, the guidance on transfer pricing documentation requires multinational enterprises (MNEs) to provide tax administrations with high-level information regarding their global business operations and transfer pricing policies in a "master file" that is to be available to all relevant tax administrations. Second, it requires that detailed transactional transfer pricing documentation be provided in a "local file" specific to each country, identifying material related party transactions, the amounts involved in those transactions, and the company's analysis of the transfer pricing determinations they have made with regard to those transactions. Third, large MNEs are required to file a Country-by-Country Report that will provide annually and for each tax jurisdiction in which they do business the amount of revenue, profit before income tax and income tax paid and accrued. It also requires MNEs to report their number of employees, stated capital, retained earnings and tangible assets in each tax jurisdiction. Finally, it requires MNEs to identify each entity within the group doing business in a particular tax jurisdiction and to provide an indication of the business activities each entity engages in
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
OECD/G20 Base Erosion and Profit Shifting Project
Series volume
Action 13: 2015 final report
http://library.link/vocab/subjectName
  • OECD
  • OECD Transfer Pricing Guidelines
  • BEPS Project (OECD)
  • transfer pricing
  • documentation requirements
  • master file
  • local file
  • CbCR
Label
Transfer pricing documentation and country-by-country reporting, Action 13 - 2015 final report
Instantiates
Publication
Extent
70 p.
Isbn
9789264241466
Isbn Type
(print)
Issn
  • 2313-2604 (print)
  • 2313-2612 (online)
Label
Transfer pricing documentation and country-by-country reporting, Action 13 - 2015 final report
Publication
Extent
70 p.
Isbn
9789264241466
Isbn Type
(print)
Issn
  • 2313-2604 (print)
  • 2313-2612 (online)

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