Category: CbC
-
CbC Report in India
In keeping with India’s commitment to implement the recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by- Country Reporting”, identified under the OECD Base Erosion and Profit Shifting (BEPS) Project, section 286 of the Income-tax Act, 1961 (‘the Act’) was inserted vide Finance Act, 2016, providing for furnishing of a…
-
CBDT notifies rules in respect of Country-by-Country reporting and furnishing of Master File in India
In keeping with India’s commitment to implement the recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, identified under the OECD Base Erosion and Profit Shifting (BEPS) Project, section 286 of the Income-tax Act, 1961 (‘the Act’) was inserted vide Finance Act, 2016, providing for furnishing of a Country-by-Country…
-
Modernized e-File (MeF) Schemas and Business Rules in USA
The following links provide (Extensible Markup Language (XML)) Schemas information, Business Rules (reject criteria), and related announcements for Software Developers and Transmitters who are interested in developing software for Modernized e-File (MeF) in USA. Schemas and Business Rules Distribution Schemas and Business Rules are available through the Registered User Portal and your e-services mailbox. Please…
-
CbC Report in the United States
Parent entities of U.S. multinational enterprise (MNE) groups with $850 million or more of revenue in a previous annual reporting period file Form 8975, Country-by-Country Report. Form 8975 is used to report a U.S. MNE group’s income, taxes paid, and other indicators of economic activity on a country-by-country basis. Ad. Form 8975 Country-by-Country Report Filing Rules International…
-
Common errors made by MNEs in preparing Country-by-Country reports
Country-by-Country (CbC) reports contain valuable information on the global allocation of the income, taxes paid and the location of economic activity among tax jurisdictions in which an MNE group operates, for use in a high level transfer pricing risk assessment, assessment of other BEPS-related risks, and economic and statistical analysis, if appropriate. However, this information…
-
Country-by-Country Reporting XML Schema
Action 13 of the OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) requires the development of “rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into consideration the compliance costs for business. The rules to be developed will include a requirement that MNEs provide all relevant governments with needed information…
-
Convention on Mutual Administrative Assistance in Tax Matters
The Convention on Mutual Administrative Assistance in Tax Matters (“the Convention“) was developed jointly by the OECD and the Council of Europe in 1988 and amended by Protocol in 2010. The Convention is the most comprehensive multilateral instrument available for all forms of tax co-operation to tackle tax evasion and avoidance. The Convention facilitates international co-operation for…
-
Compilation of approaches adopted by jurisdictions
OECD Guidance on the Implementation of Country-by-Country Reporting contains a number of items of interpretative guidance prepared in response to questions raised by tax authorities and business on aspects of the BEPS Action 13 minimum standard. Several of these items of guidance provide flexibility for jurisdictions to take different approaches including, in particular: (i) whether…
-
Domestic legal frameworks for Country-by-Country (CbC) reporting around the world
The table below contains information on the domestic legal frameworks for Country-by-Country (CbC) reporting around the world. It provides a high-level snapshot for tax administrations and MNE Groups as to the first reporting periods, availability of surrogate filing including in the parent jurisdiction, and local filing. This table contains the information received from members so…
-
Guidance on the Implementation of Country-by-Country Reporting
Ad. 1. Introduction All OECD and G20 countries have committed to implementing Country-by-Country reporting, as set out in the Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting”. Recognising the significant benefits that CbC reporting can offer a tax administration in undertaking high level risk assessment of transfer pricing and other BEPS related tax risks,…
CbC Reporting 