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OECD releases BEPS country by country reporting package

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The OECD has published its package of model legislation and competent authority agreements to help tax administrations implement the proposed requirement for multinational companies to report transfer pricing information on a country by country basis, starting in 2016.

The Country by country reporting implementation package will, according to the OECD, ‘facilitate a consistent and swift implementation of new transfer pricing reporting standards developed under action 13 of the BEPS action plan, ensuring that tax administrations obtain a complete understanding of the way multinational enterprises (MNEs) structure their operations, while also ensuring that the confidentiality of such information is safeguarded’.

‘Country by country reporting requirements will require MNEs to provide aggregate information annually, in each jurisdiction where they do business, relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group, as well as information about which entities do business in a particular jurisdiction and the business activities each entity engages in,’ the OECD added.

‘The new implementation package consists of model legislation requiring the ultimate parent entity of an MNE group to file the country-by-country report in its jurisdiction of residence, including backup filing requirements when that jurisdiction does not require filing. The package also contains three Model Competent Authority Agreements to facilitate the exchange of country-by-country reports among tax administration. The model agreements are based on the Multilateral Convention on Administrative Assistance in Tax Matters, bilateral tax conventions and Tax Information Exchange Agreements (TIEAs).’

The package was approved by the countries participating in the OECD/G20 BEPS Project at the last meeting of the OECD Committee on Fiscal Affairs, held on 27–28 May. See