On the 19 July 2013 BEPS Action Plan, the OECD was directed to “develop rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into account the compliance costs for business.
The rules to be developed will include a requirement that MNE’s 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”.
This paper contains an initial draft of revised guidance on transfer pricing documentation and country
by country reporting. It is submitted for comment by interested parties.
The draft template, which is subject to comments and a public consultation, requires a company for each country in which it operates to list their “constituent entities,” effective place of management, and important business activities.
In addition, the draft template would also require a company to report on a country-by-country basis:
its revenues, earnings before income tax, income tax paid on a cash basis to the country of organization and to all other countries, total withholding tax paid, stated capital and accumulated earnings, number of employees, total employee expense, tangible assets other than cash and cash equivalents, royalties paid to constituent entities, royalties received from constituent entities, interest paid to constituent entities, interest received from constituent entities, service fees paid to constituent entities, and service fees received from constituent entities.
Need Advice on How to Prepare for BEPS?
Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888 882-9243)