ACTION Point 13 of the BEPS Report is about TP
documentation and country by country reporting. Having got the mandate
of the G20 forum the OECD has today come out with guidance notes for better
comprehension of MNEs.
The
Guidance sets out:
++
Transitional filing options for MNEs that voluntarily file in the Parent
jurisdiction;
++ Guidance on the application of CbC reporting to investment funds;
++ Guidance on the application of CbC reporting to partnerships; and
++ The impact of exchange rate fluctuations on the agreed EUR 750 million filing
threshold for MNE groups.
The OECD has stated that it will continue to support the consistent and swift
implementation of CbC reporting to ensure a level playing field, but also provide
certainty for taxpayers and improve the ability of tax administrations to use
CbC reports in their risk assessment work. Where additional questions of interpretation
arise and would be best addressed through common guidance, the OECD will endeavour
to make this available.
|