UK and International Tax news
OECD Issues Implementation Package On Action 13 And CbC Reporting
Wednesday 17th June 2015
The OECD has recently released a package of measures for the implementation of a new CbC Reporting plan developed under the OECD/G20 BEPS Project.
The OECD had issued guidance on the implementation of transfer pricing documentation and CbC reporting in February 2015 which followed on from the September 2014 report “Guidance on Transfer Pricing Documentation and Country by Country Reporting”.
The February 2015 guidance set out details of the timing of preparation and filing of the CbC Report, which MNE groups should be required to file the CbC Report, the necessary conditions underpinning the obtaining and use of the CbC Report by jurisdiction, and the framework for government to government mechanisms to exchange CbC Reports together with the work plan for developing an implementation package.
It also recommended that the master file and local file elements of the new transfer pricing documentation standard be implemented through local country legislation or administrative procedures and that they be filed directly with the tax administration in each relevant jurisdiction as required by those administrations.
The new implementation package consists of model legislation requiring the ultimate parent entity of an MNE group to file the CbC report in its jurisdiction of residence, including backup filing requirements when that jurisdiction does not require filing.
The package also contains three model Competent Authority Agreements to facilitate the exchange of CbC reports among tax administrations. The model agreements are based on the Multilateral Convention on Administrative Assistance in Tax Matters, bilateral tax conventions and Tax Information Exchange Agreements.
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