On 19 July 2013 the OECD released an Action Plan on Base Erosion and Profit Shifting (BEPS). One of the 15 specific actions was to re-examine transfer pricing (‘TP’) documentation with a deadline of September 2014. The Action Plan outlines that the re-examination seeks to increase transparency and ‘include a requirement... to provide all relevant governments with... information on... global allocation of the income, economic activity and taxes paid among countries according to a common template’. Accordingly, the concept of Country-by-Country (‘CbC’) reporting was born.
On 30 January 2014, a public consultation document Discussion Draft on Transfer Pricing Documentation and CbC Reporting was issued. Any comments are to be submitted by 23 February 2014.