OECD/G20 Base Erosion and Profit Shifting Project

2313-2612 (online)
2313-2604 (print)
Hide / Show Abstract

Addressing base erosion and profit shifting is a key priority of governments around the globe. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 BEPS Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. A key focus of this work is to eliminate double non-taxation. However in doing so, new rules should not result in double taxation, unwarranted compliance burdens or restrictions to legitimate cross-border activity.

Also available in French, German, Spanish
Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report You or your institution have access to this content

Click to Access: 
  • PDF
  • http://www.keepeek.com/Digital-Asset-Management/oecd/taxation/transfer-pricing-documentation-and-country-by-country-reporting-action-13-2015-final-report_9789264241480-en
  • READ
05 Oct 2015
9789264241480 (PDF) ;9789264241466(print)

Hide / Show Abstract

This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach  will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports.

Also available in French, German, Spanish
loader image

Table of Contents

Chapter V of the Transfer Pricing Guidelines on Documentation

Annex I to Chapter V. Transfer pricing documentation – Master file

Annex II to Chapter V. Transfer pricing documentation – Local file

Annex III to Chapter V. Transfer pricing documentation – Country-by-Country Report

Annex IV to Chapter V. Country-by-Country Reporting Implementation Package

Visit the OECD web site