The OECD wants to know whether its Country-by-Country Report minimum standard is effective
The OECD is asking stakeholders for feedback on its Country-by-Country Report (CbC report) minimum standard. In a new 70-page consultation document, the OECD outlines questions about the implementation, scope and reporting of CbC information under Action 13 of its BEPS Action plan. The OECD will accept comments on the document until March 6, 2020, and intends to complete this review by the end of 2020, as required under Action 13.
In its BEPS Action plan, the OECD called for the development of transfer pricing documentation rules to enhance transparency for tax administrations. Specifically, Action 13 established a three-tiered standardized approach to transfer pricing documentation, including a CbC report that provides details of a multinational group's revenues, profit before tax, tax accrued and other information relevant to a high-level risk assessment, for each tax jurisdiction in which the group has a constituent entity. CbC reporting is one of four BEPS minimum standards which all members of the Inclusive Framework have committed to implement.
Canada implemented CbC reporting rules in 2016, applicable to fiscal years beginning after 2015.
In its public consultation document, the OECD focuses on tax administrations' use of CbC reports during high-level transfer pricing risk assessments, assessments for other BEPS-related risks and economic and statistical analysis. The OECD asks specific questions in three areas:
The OECD will also hold a public consultation meeting on CbC reporting on March 17, 2020, at the OECD Conference Centre in Paris.
Information is current to February 18, 2020. 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
© 2021 KPMG LLP, an Ontario limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.