Transfer pricing documentation and country by country reporting

Tom McFarlane

Speed read

Action 13 has, without a doubt, generated widespread activity amongst tax authorities and legislators. It is clear that as a result of Action 13, tax authorities will have significantly more information available to them to undertake transfer pricing risk assessments. This increase in transparency has inevitably led to concern amongst MNEs – as has the likely increase in compliance requirements which puts further strain on MNEs’ resources. The UK, as an early proponent of CBCR, has moved quickly to implement the recommendations laid out in Action 13. Effective for accounting periods beginning 1 January 2016, UK MNEs with group annual turnover greater than £586m must start putting in processes and strategies now, so that there are no surprises post 2017.

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