One of the BEPS Action Points requires Multinational Enterprises (MNEs) to report information on a Country-by-Country (CbC) basis relevant to the risk assessment and examination of their underlying Transfer Pricing documentation.
The OECD’s final report was published on 5 October 2015 and contains guidance on Transfer Pricing Documentation and CbC-Reporting that replaces their previous 2010 Transfer Pricing Guidelines. The OECD Master File and CbC-Reporting concepts are now being implemented worldwide into national tax law. Jurisdictions such as Australia have already started on this path, with the CbC reports for years ended 31 December 2016 now lodged.
The implementation of BEPS may vary substantially across various tax jurisdictions around the globe, and multinationals will need to be aware of how the laws apply in jurisdictions where they operate.
International Transfer Pricing experts from Roedl & Partner Public Accountants Germany have produced an excellent overview of the implementation status regarding the OECD Master File and CbC-Reporting concepts in different countries.
This coverage includes a useful pdf summary of the latest status OECD Master File-concept and CbC Reporting – national implementation released May 2018.
Accru Felsers has a long relationship with Roedl & Partner, having worked closely with their global team on international tax matters for German-Australian businesses for decades. We currently assist many of our clients with transfer pricing matters. Please contact us if you need assistance.