OECD Guidelines on CbyCcTransfer Pricing Documentation | KPMG | CA

OECD Guidelines on Country-By-Country Transfer Pricing Documentation

OECD Guidelines on CbyCcTransfer Pricing Documentation

The OECD recently released implementation guidance on filing a country-by-country report under the BEPS Action Plan 13.

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The OECD recently released implementation guidance on filing a country-by-country report under the BEPS Action Plan 13, "Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting". In particular, the implementation guidance states that a €750 million threshold would exclude 85% to 90% of multinational enterprises from having to file the required country-by-country form, but would capture 90% of corporate revenues.

KPMG observations

It appears that, if implemented, companies beneath the €750 million threshold (approximately $855 million U.S.) would not have to file a country-by-country form. However, the OECD and G20 will review the implementation of the new standard in 2020, and consider the appropriateness of the revenue threshold, as well as whether additional or other data needs to be reported on the form.

Additionally, multinational enterprises that meet or exceed the revenue threshold need to start planning for country-by-country because 2015 may be the last year for which the information will not be reported in the country-by-country template.

For more information, contact your KPMG adviser.

Disclaimer

Information is current to February 17, 2015. 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

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