Category: Country-by-Country (CbyC) Reporting

GAO-17-103, International Taxation: Information on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing, January 27, 2017

What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of… – Continue reading

New transfer pricing requirements in Latin America under BEPS

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading

German Multinationals Fear Disclosure of Global Tax Reports

Multinational companies headquartered in Germany worry that when they report their global tax and profits for 2016, some countries will leak their country-by-country reports to the press. German parents of multinational groups with annual consolidated group revenue of at least 750 million euros ($797 million) are required to file, with… – Continue reading

Register of people with significant control will not affect Crown territories

The government has quashed calls to look at extending the requirement to publish a public register of people with significant control to companies incorporated in the Crown dependencies and overseas territories, as part of a bid to increase tax transparency, saying new rules on the automatic exchange of information are… – Continue reading

Cyprus: Country-By-Country Reporting Under Base Erosion And Profit Shifting Action 13

Cyprus signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by Country Reports between its member states on 1 November 2016 after approval by the Council of Ministers at its meeting held on 28 September 2016. Following publication in the government gazette… – Continue reading

Switzerland: Federal Council Adopts Dispatch On Exchange Of Country-By-Country Reports

On 23 November 2016, the Swiss Federal Council adopted the dispatch on the Multilateral Agreement on the exchange of Country-by-Country Reports (CbCRs) and draft federal implementing legislation. The proposal is aimed at implementing the minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting… – Continue reading

Multinational CFOs increasingly view tax as reputational risk

Tax directors and CFOs at multinational companies are facing increasing numbers of tax audits, and are becoming concerned about the impact of public perception of their tax planning on their company’s reputation, according to research by Taxand. Its fifth annual global survey of CFOs, tax and finance directors across Europe,… – Continue reading

Saint-Amans: greater co-operation the only way to maintain tax sovereignty

Tax sovereignty is incompatible with the globalised world, according to OECD tax policy director Pascal Saint-Amans Speaking at the Public Accounts Committee’s Global Tax Transparency Summit, Saint-Amans told told ministers, tax professionals and international representatives ‘a gap’ still exists ‘between the world globalising and tax sovereignty’. ‘As members of parliament,… – Continue reading

Cayman commits to BEPS rules to counter EU blacklist

Also commits to country-by-country reporting Cayman has committed in principle to a project reforming the application of tax rules in cross-border business to combat the erosion of tax bases and the artificial shifting of profits to low or no-tax jurisdictions. Developed by the Organization for Economic Cooperation and Development, base… – Continue reading

Ukraine officially joins BEPS project

On November 22, 2016, the Minister of Finance of Ukraine handed an official letter on Ukraine’s accession to the BEPS (Base Erosion and Profit Shifting) plan to the Secretary-General of OECD. Being the final stage in the process of joining the project, Ukraine is to become a member of the… – Continue reading

German chemicals firm BASF avoided nearly €1bn in tax, says report

Network of foreign subsidiaries reported key to €923 million windfall over five years German chemicals manufacturer BASF has been accused of avoiding close to €1 billion of tax. In a report published on Monday, the company is alleged to have used aggressive tax-planning strategies in the Netherlands, Belgium, Switzerland and… – Continue reading

Country-by-Country Confusion: Narrow BEPS Queries Abound

Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading

MENA Transfer Pricing in a Post BEPS World

Historically, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global… – Continue reading

Deal signed to counter profit shifting Read more at:

New Chief Minister Howard Quayle MHK has restated the island’s commitment to tax transparency at an Organisation for Economic Co-operation and Development event in Paris. Mr Quayle was in Paris for the Manx government’s signing of a new OECD agreement on automatic exchange of country by country reporting by large… – Continue reading

Singapore Issues Guidance On CbC Reporting

The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory. The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS. For… – Continue reading

EU to black list tax havens, EU Commissioner Moscovisi says

A list on non-cooperative tax jurisdictions around the world, the first ever common EU list, is being under preparation, Commissioner for Economic and Financial Affairs, Taxation and Customs Pierre Moscovici has said. “This month, we started the process that will lead, by the end of 2017, to the first ever… – Continue reading

Base erosion and profit shifting protocol: Small firms may get relief

The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading

China Introduces Sweeping New Transfer Pricing Rules

China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading

Introduction of Stringent Transfer Pricing Documentation Requirement

A recent 2016 tax reform in Japan (“Reform”) has introduced stringent Japanese Transfer Pricing Documentation Requirements, which require the preparation/filing of: (i) a Master File, (ii) a Country-by-Country Report, and (iii) a Local File, as well as (iv) a “Notification of the Ultimate Parent Entity.” Any ultimate parent company (“Parent… – Continue reading

Liechtenstein Ratifies Multilateral CbC Report Pact

On August 22, 2016, Liechtenstein filed its instrument of ratification of the Multilateral Competent Authority Agreement on country-by-country (CbC) reporting. With the move, Liechtenstein will be able to share the information contained in the CbC reports with tax treaty partners that have implemented the necessary reporting standards. Liechtenstein was among… – Continue reading

Closing tax avoidance loopholes

THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading

EU and OECD Transfer Pricing Documentation Procedures after Brexit

Transfer pricing documentation rules have come to the fore with the United Kingdom’s Brexit. The European Union and the Organization for Economic Cooperation and Development appear to apply similar transfer pricing documentation rules to multinational companies, but differences nevertheless abound. Some multinational enterprises may view these differences as nuances, but… – Continue reading

Nations discuss corporate tax avoidance at OECD meeting in Kyoto

Representatives of more than 80 countries and jurisdictions met in Kyoto on Thursday for a two-day conference aimed at going after corporate tax avoidance in the first-ever effort of its kind to include developed and developing countries. The meeting of the Organization for Economic Cooperation and Development’s Committee on Fiscal… – Continue reading

Proposed IRS Country-by-Country Reporting Regulations: What Do They Mean for You?

Genesis of CbC Reporting and How it will Affect U.S. Multinational Enterprises Country-by-country (CbC) reporting is essentially exactly what it sounds like: a report that shows every country where a multinational enterprise (MNE) operates and allocates income, earnings and pays taxes. The CbC report regulations proposed by the Internal Revenue… – Continue reading

EU to force tax disclosure from largest multinationals

Multinationals with turnover of more than €750 million would have to publish profit and tax details on their websites under new European Commission plans, the Financial Times has reported. According to plans seen by the Financial Times, the Commission would impose the requirement on companies with subsidiaries in Europe as… – Continue reading

AICPA Offers Recommendations to IRS on Country-by-Country Reporting

The American Institute of CPAs has written to the Internal Revenue Service recommending some changes in the IRS’s proposed regulations for country-by-country reporting by multinational corporations of financial information to curb tax avoidance. The proposed regulations were issued last December as part of an effort by the Organization of Economic… – Continue reading

Union Budget 2016 – International tax proposals

With the adoption of the BEPS package, OECD and G20 countries laid the foundations of a modern international tax framework under which profits would be taxed where economic activity and value creation occurs. It is now time to focus on implementation of the recommended changes in a consistent and coherent… – Continue reading

Country by Country Reporting – Any contours?

Transfer pricing (TP) issues have never been such a critical part of the global economic agenda as they are today. Following the release of the report addressing Base Erosion and Profit Shifting (BEPS) in February 2013, OECD and G20 countries (including India) adopted a 15-point Action Plan to address BEPS… – Continue reading

Mandatory disclosure of tax bills closer as Australia joins OECD push

Australia is one of 31 countries to sign an agreement in Paris to confidentially share tax information on multinational companies in a bid to stamp out tax avoidance. The deal comes as Apple has taken advantage of accounting rules in its local business that could allow it to pay virtually… – Continue reading

Fair Taxation: Commission presents new measures against corporate tax avoidance

Today’s proposals aim for a coordinated EU wide response to corporate tax avoidance, following global standards developed by the OECD last autumn. New rules are needed to align the tax laws in all 28 EU countries in order to fight aggressive tax practices by large companies efficiently and effectively. The… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

BEPS rules to be made compulsory from 1 April

India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21:Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and Profit… – Continue reading

The Netherlands implements OECD BEPS Country-by-Country Reporting as well as the amendments to the EU Parent-Subsidiary Directive

As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21: Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and… – Continue reading