Cyprus: OECD Releases New Measures For Implementation Of A BEPS Country By Country Reporting Plan

On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded on the Guidance on the Implementation of Transfer Pricing Documentation and CbC Report of September 2014 and on the CbC reporting proposals and transfer pricing documentation issued in February 2015 and will facilitate the implementation of new transfer pricing reporting standards developed under Action 13 of the BEPS Action Plan.

As the OECD confirmed: “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…” and “will require MNEs to provide aggregate information annually, in each jurisdiction where they do business, relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group, as well as information about which entities do business in a particular jurisdiction and the business activities each entity engages in.”

A few of the key elements of the CbC Implementation Package include focus on Confidentiality and data safeguards and specific rules on appropriate use of CbC reports. The CbC Implementation Package includes model legislation and requires that the ultimate parent entity of an MNE group file the CbC report in its jurisdiction of residence, even in instances where the said jurisdiction does not require filing.

The package also contains three Model Competent Authority Agreements to facilitate the exchange of CbC reports among tax administration. They are based on the Multilateral Convention on Administrative Assistance in Tax Matters, bilateral tax conventions and Tax Information Exchange Agreements (TIEAs).

On the 27-28 May 2015 the Implementation Package was approved by the countries participating in the G20/BEPS Project at the last meeting, held by the Committee on Fiscal Affairs.

For further information on the Country by Country Reporting Implementation Package issued by the OECD and to download the full report please click here.

http://www.rsmniehelanceekooij.nl/media/uploads/files/News_alert_OECD_OECD_releases_implementation_package_for_BEPS.pdf

http://www.bdo.be/en/news/professional-news/2015/beps-update/

http://www.internationaltaxplaza.info/homepage/news-archive/news-archive-june-2015/1049-oecd-releases-implementation-package-for-beps-country-by-country-reporting

http://www.ey.com/GL/en/Services/Tax/International-Tax/Alert–OECD-issues-implementation-guidelines-for-country-by-country-reporting-under-BEPS-Action-13

https://www.accountancylive.com/oecd-releases-implementation-rules-country-country-tax-reporting

http://www.oecd.org/newsroom/first-steps-towards-implementation-of-oecd-g20-efforts-against-tax-avoidance-by-multinationals.htm

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