Transfer Pricing News Issue 32 - December 2019

Further OECD guidance on Country-by-Country Reporting

The OECD has released additional interpretative guidance to tax administrations and MNE Groups on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13), to give greater certainty on this area.

The new guidance is mainly on the treatment of dividends received, the operation of local filing, the use of rounded amounts in Table 1 of an MNE Group’s CbC report and the information that must be provided with respect to the sources of data used.

The OECD has also published a summary of common errors made by MNE Groups in preparing CbC reports, with the aim of helping MNE Groups avoiding these errors and tax administrations in detecting them.

Transfer pricing of financing transactions: OECD guidance

Anton Hume and Andrew Stewart of BDO in the United Kingdom authored “The transfer pricing of financing transactions: OECD guidance”, published by Tax Journal on 15 November 2019.

The article includes:

  • Why do we need new guidance?
  • Content of the guidance
  • Wider factors relating to tax authority attitude.

We trust that you will find the article informative and helpful.

Anton Hume