OECD releases discussion draft on Transfer Pricing (TP) documentation and Country-by-Country reporting under BEPS Action Plan; Suggests two-tiered approach to TP documentation containing master file and local file; Information in master file provides MNE groups “blueprint”, to contain details in five categories: a) MNE group’s organisational structure; b) description business; c) intangibles; d) inter-company financial activities; and (e) financial and tax positions; Master file to contain common standardised information relevant for all MNE group members; Local file helps to meet the objective of assuring that taxpayer has complied with arm’s length principle in its material TP positions affecting a specific jurisdiction; While master file and local file in general be updated annually, tax administrators may determine that database searches in local file be updated after every 3 years; Discussion draft also contains model template of Country-by-Country reporting details, which includes details of place of management of each entity, revenue, earnings, tax paid, number of employees, etc
Posted on: Sat, 01 Feb 2014 05:50:12 +0000
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