OECD releases additional guidance on implementation of the Country-by-Country (CbC) reporting (BEPS Action 13)

  • By A&S
  • April 7, 2017
  • News

On April 6, 2017, the Inclusive Framework on BEPS released additional guidance to provide essential information on implementation of the Country-by-Country (CbC) reporting (BEPS Action 13). The updated CbC guidance document contains additional information clarifying several interpretation issues related to the data to be included in the CbC report…

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OECD publishes additional guidance on Country-by-Country Reporting (BEPS Action 13)

  • By A&S
  • June 30, 2016
  • News

On June 29, 2016, the OECD published a memorandum titled Guidance on the Implementation of Country-by-Country (CbC) Reporting. As described in the original press release, the OECD/G20 BEPS Project set out 15 key actions to reform the international tax framework and ensure that profits are reported where economic activities…

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European Council adopts rules on CbC reporting, first reports to cover fiscal year 2016

  • By A&S
  • May 27, 2016
  • News

On May 25, 2016, the European Council adopted rules on the reporting by multinational companies of tax-related information and exchange of that information between member states. The accepted Council Directive, amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation, will implement OECD anti-BEPS Action…

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European commission proposes public country-by-country tax transparency rules for multinationals

  • By A&S
  • April 12, 2016
  • News

On April 12, 2016, the European Commission (the Commission) introduced a proposal to amend the Accounting Directive (Directive 2013/34/EU) in order to create public country-by-country tax transparency rules for multinational enterprises operating in the EU. Supplementing other proposals to introduce sharing of information between tax authorities, the new rules…

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31 countries sign agreement to enable automatic sharing of CbC information

  • By A&S
  • January 28, 2016
  • News

On January 28, 2016, 31 countries* signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country (CbC) reports. The MCAA will enable consistent and swift implementation of new transfer pricing reporting standards developed under Action 13 of the BEPS Action Plan. With CbC reporting tax administrations where a company operates will…

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Jersey launches consultation regarding introduction of country-by-country reporting

  • By A&S
  • January 28, 2016
  • News

The Jersey Chief Minister’s department has issued a consultation document and invites comments regarding the proposed introduction of a country-by-country (CbC) reporting obligation. The obligation is in line with Action 13 of the OECD BEPS project. Additional information can be found on the Jersey government website.

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France publishes corporate tax, transfer pricing legislation

  • By A&S
  • January 20, 2016
  • News

France has published new corporate tax and transfer pricing legislation in the official journal, which includes: Modifications to the parent-subsidiary regime; Revisions to the withholding tax exemption regime for dividends paid to EU parent companies; Modifications to the taxation regime of intra-group dividends paid between EU entities; Rules for…

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Finland requesting comments on proposal revising transfer pricing documentation rules, introducing Country-by-Country reporting

  • By A&S
  • January 12, 2016
  • News

The Finnish Ministry of Finance has release a proposal for public comment, which includes revisions to the transfer pricing documentation rules and the introduction of country-by-country (CbC) reporting. The draft bill generally follows the OECD’s recommendations outlined in Action 13 (Transfer pricing documentation and country-by-country reporting) of the BEPS…

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New transfer pricing documentation rules enacted in the Netherlands, includes Country-by-Country reporting

  • By A&S
  • January 11, 2016
  • News

The Dutch Upper House (Eerste Kamer) has passed legislation (‘2016 Other Tax Measures’, in English) amending the transfer pricing documentation rules to include country-by-country reporting obligations, as well as master file and local file provisions. The rules are effective from January 1, 2016. The legislation introduces new standardized documentation…

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Ireland publishes regulations, includes Country-by-Country reporting requirements

  • By A&S
  • January 8, 2016
  • News

The Irish Revenue published the Taxes (Country-by-Country Reporting) Regulations 2015, which includes the following specifications: The entities other than the multinational group parent company that must provide (equivalent) Country-by-Country (CbC) reports; The notification obligations for the resident group parent company, surrogate parent company and constituent entities of a multinational…

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