Countries implementing transfer pricing documentation | KPMG | BE

BEPS update: Countries implementing transfer pricing documentation, country-by-country reporting (table)

Countries implementing transfer pricing documentation

This KPMG report summarizes, in table format, a list of countries that either intend to enact, or have already enacted by the end of 2015, laws implementing country-by-country (CbC) reporting and other transfer pricing disclosure requirements based on Action 13 of the OECD’s base erosion and profit (BEPS) action plan. Read more at the hyperlinks provided below.


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The Australian Parliament on 3 December 2015 passed the multinational anti-avoidance rule (i.e. Australia's “de facto” diverted profits tax regime) and the CbC reporting regime. The new rule also foresees the amendment of tax laws governing the Australian Taxation Office (ATO) public disclosures of tax return data to now include Australian owned private companies with annual income of A$200 million or more, as well as the requirement for Australian businesses of multinational corporations with global income of A$1 billion or more to prepare general purpose financial reports for years commencing on or after 1 July 2016.

In addition, the ATO on 17 December 2015 released guidelines that address CbC reporting. Read TaxNewsFlash

Denmark The Danish Parliament on 18 December 2015 passed legislation to require CbC reporting. Multinational groups whose ultimate parent company is a resident in Denmark will be required to make CbC reporting submissions. The CbC reporting rules will also affect foreign group entities that are residents in Denmark if certain conditions are met. Read TaxNewsFlash
France The French Parliament on 18 December 2105 passed the Finance Bill for 2016, including a provision requiring CbC reporting for the largest multinational enterprises. Contrary to the initial proposal, the disclosure will not be made public. Read TaxNewsFlash
Ireland The president on 22 December 2015 signed into law Finance Act 2015 that includes rules following the OECD's recommended CbC reporting requirements. The Finance Act provision closely mirrors the OECD’s suggested model legislation. Read TaxNewsFlash
Italy The 2016 budget law passed on 22 December 2015 includes CbC annual reporting requirements for multinational entities pursuant to the BEPS recommendations. Read TaxNewsFlash
Japan The Japanese government’s ruling coalition on 16 December 2015 agreed to tax reform proposals, including CbC reporting based on the BEPS Action 13 recommendations. Read TaxNewsFlash
Korea Korea’s Parliament on 2 December 2015 approved legislation to implement BEPS Action 13 recommendations. The rules require all Korean domestic corporations and all foreign corporations with a domestic place of business in Korea that are engaged in certain cross-border related-party transactions to file both master file and local file reports. Read TaxNewsFlash
Poland New law in Poland expands the requirements for transfer pricing documentation and includes CbC reporting. The new provisions essentially reflect the recommendations made in BEPS Action 13, and provide for CbC, master file and local file reporting. The legislation was passed by the Lower House in September 2015 and the president signed the law on 27 October 2015. Read TaxNewsFlash
United States The Treasury Department and IRS on 21 December 2015 released proposed regulations that would require annual CbC by U.S. persons that are the ultimate parent entity of a multinational enterprise (MNE) group. Read TaxNewsFlash

Read more in a January 2016 report prepared by the KPMG member firm in Luxembourg: Luxembourg Tax Alert

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