Services on preparing three-tiered reporting according to BEPS13 requirements

The Organization for Economic Cooperation and Development (OECD) Action Plan on Base Erosion and Profit Shifting (BEPS) developed and published in 2013 brings together more than 130 countries and jurisdictions to work together to implement the BEPS plan.

Under BEPS Action 13 (Action 13 or BEPS13) the OECD developed rules on disclosure of information by constituent entities of multinational enterprise groups (MNE Groups) according to a three-tiered approach to documentation (Country-by-Country Report (CbCR), Master File and Local File). In the Russian legislation BEPS13 recommendations are reflected in Federal Law No. 340-FZ dated 27.11.2017 and in Chapters 14.4 and 14.4-1 of the RTC regulating the approach to formulating intercountry requirements.

KPMG will be pleased to provide the following services to Russian taxpayers that are constituent entities of MNE Groups:

  • Preparation of necessary documents in accordance with the requirements of the Russian tax laws:
  • Value chain analysis and management:
    • Mapping value creation processes and identification of key companies, processes, assets and risks
    • Services to identify the correspondence between the real activities of companies and their contractual relations, recommendations to change the operational and contractual structure of relations between group companies
    • Structuring international transactions in line with the current BEPS trends in the Russian and foreign jurisdictions