Global tax alert
OECD releases draft country-by-country reporting template for comment
On 30 January 2014, the Organisation for Economic Cooperation and Development (OECD) released the much-anticipated draft of its proposed template for country-by-country reporting to tax authorities in its Discussion Draft on Transfer Pricing Documentation and CbC Reporting (Discussion Draft). The OECD Discussion Draft also elaborates on the OECD’s White Paper on Transfer Pricing Documentation which was released on 30 July 2013. (See EY Global Tax Alert, OECD invites public comments on the White Paper on Transfer Pricing Documentation dated 1 August 2013.)
The proposals described in the Discussion Draft are being developed pursuant to the OECD Base Erosion and Profit Shifting (BEPS) Action Plan, which was issued on 19 July 2013. (See EY Global Tax Alert, OECD releases Action Plan on Base Erosion and Profit Shifting (BEPS), dated 19 July 2013.) These proposals are being released in draft form to provide an opportunity for stakeholders to comment.
The Discussion Draft sets forth proposed revisions to the OECD Transfer Pricing Guidelines that describe a common approach to transfer pricing documentation to be adopted by countries. The proposed two-tier approach would involve a global master file together with local country files.
The Discussion Draft includes a proposed country-by-country reporting template which would require multinational company (MNC) groups to provide extensive information for each entity in the group.
This Alert focuses in particular on the details of the draft country-by-country reporting template.