As tax administrations and international economic organizations reach consensus for implementing international measures that will promote tax transparency amongst the business community, uncertainties rise around the scope and extent of some of the action points proposed to drive tax transparency between jurisdictions. For example, the implementation of Action plan 13.
Action plan 13 of the OECD’s BEPS initiatives addresses ‘Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting’. The aim of this action plan is to enhance transparency for tax administrations by providing them with adequate information to conduct transfer pricing risk assessments and examinations. To tackle these issues, Action plan 13 introduced a four-tiered approach that should allow tax administrations to compile relevant data on how multinational companies allocate taxable revenues and liabilities across the various countries where they operate: Tier 1) a Masterfile, Tier 2) a Local file, Tier 3) Country by Country reporting (CbC) and Tier 4) Local transfer pricing forms.
Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.
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