BEPS: What lies within your country-by-country transfer pricing

On October 5, 2015, the OECD released its package of final reports under the OECD/G20 Base Erosion and Profit-Shifting Project (BEPS). Action 13 of the BEPS Action Plan contains the OECD’s new guidance on a standardized three-tiered approach to transfer pricing documentation and introduces a requirement for large multinational enterprises (MNEs) to provide governments with information on their global allocation of income, economic activity, and taxes paid among countries according to a common template —the Country-by-Country Report (CbC Report). In light of the new CbC Report, CRA has developed a proprietary diagnostic tool that uses CbC data to provide insight into a company’s global transfer pricing position, based on BEPS concepts of value creation and risk alignment. To read more, click the link below.