On 5 October 2015, the OECD/G20 delivered, in the context of the Base Erosion and Profit Shifting (BEPS) Project, the final Action 13 report (Transfer Pricing Documentation and Country-by-Country reporting). This report includes revised standards for transfer pricing documentation and a template for Country-by-Country (CbC) reporting.
The BEPS Action 13 Report recommends that the CbC reporting takes place with respect to fiscal periods commencing from January 2016. However, countries are at various stages of implementation. This Tax Insight summarises the current status of CbC reporting obligations in various European jurisdictions, as listed below.
CbC reporting is a key component of the global trend towards greater tax transparency by MNE groups.
We have summarised the framework of the requirements for each of the selected countries. It is worth noting the importance of the decision of the MNEs on where to file the CbC, based on each country's specific regulations on surrogate, voluntary filing or secondary filing options, as well as the notification requirements of each country.
For further information please contact Joel Cooper or the relevant country author.