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

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