Global Tax Adviser, February 02, 2016. Meghan Beer GTA, International Corporate Tax. Representatives of 31 countries have now signed an agreement for the automatic exchange of country-by-country reports. This brings the number of signatories to the Multilateral Competent Authority Agreement (MCAA) up to 79. Although Canada has yet to introduce country-by-country legislation, any taxpayers with operations in these countries will have to get ready for this reporting now. The MCAA is intended to allow for consistent implementation of new transfer pricing reporting standards developed under Action 13 of the OECD's base erosion and profit shifting (BEPS) project (see CTN 15-48). It will also allow tax administrations to understand how multinational enterprises structure their operations and to protect confidential information.
Canada has signed the MCAA and selected September 2018 as the intended time by which the first information exchange of country-by-country reporting will be activated. (See CTN 15-25.)
Although the U.S. is not listed as a signatory to the MCAA, it has introduced proposed country-by-country regulations (see CTN 16-01). The IRS intends to share its country-by-country reports with other countries' tax administrations under bilateral tax treaties and TIEAs.
Given that a number of other countries have already introduced country-by-country reporting (e.g., Australia, U.K.) and all the MCAA signatories that intend to do so, taxpayers should be preparing for country-by-country reporting because they will be required to report within those countries.
For more details, contact your KPMG adviser.
Information is current to February 02, 2016. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500