Global

Details

  • Service: Tax, Global Transfer Pricing Services, International Tax
  • Type: Regulatory update
  • Date: 10/10/2013

OECD - Memo on transfer pricing documentation, country-by-country reporting 

October 10:  Action 13 in the BEPS Action Plan* calls on the Organisation for Economic Co-operation and Development (OECD) to develop requirements for taxpayers to report income, taxes paid, and indicators of economic activity to governments according to a common template.

*OECD Action Plan on Base Erosion and Profit Shifting (BEPS) released 19 July 2013.


According to the OECD, the language of the BEPS Action Plan makes it clear that such country-by-country reporting to governments will be an essential element of transfer pricing documentation proposals being developed by the OECD Working Party 6 (WP 6).


The OECD on 12-13 November 2013 will hold a public consultation on various matters, including the OECD “white paper” [PDF 461 KB] on transfer pricing documentation (July 2013) and associated issues including country-by-country reporting under the BEPS Action Plan.


Noting there are important implementation issues to be addressed in developing a credible proposal regarding country-by-country reporting, the OECD issued a memo that summarizes responses to certain questions relevant to the development of a country-by-country reporting template, including:


  • What information would be required?
  • What mechanisms would be developed for reporting and sharing country-by-country data?

Read the OECD October 2013 memo [PDF 118 KB] Memorandum on Transfer Pricing Documentation and Country by Country Reporting



Contact a tax professional with KPMG's Global Transfer Pricing Services.




©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now