Annex III to Chapter V of these Guidelines contains a model template for the Country-by-Country Report together with its accompanying instructions.
TPG2017 Chapter V paragraph 5.26
Category: C. A three-tiered approach to transfer pricing documentation, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter V: Documentation | Tag: Country-by-Country Reporting, Transfer pricing documentation
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- TPG2022 Chapter V paragraph 5.27Each taxpayer should endeavour to determine transfer prices for tax purposes in accordance with the arm’s length principle, based upon information reasonably available at the time of the transaction. Thus, a taxpayer ordinarily should give consideration to whether its transfer pricing is appropriate...
- TPG2022 Chapter V paragraph 5.59Jurisdictions should use appropriately the information in the Country- by-Country Report template in accordance with paragraph 5.25. In particular, jurisdictions will commit to use the Country-by-Country Report for assessing high-level transfer pricing risk. Jurisdictions may also use the Country-by- Country Report for assessing...
- TPG2022 Chapter V paragraph 5.35Taxpayers should not be obliged to retain documents beyond a reasonable period consistent with the requirements of domestic law at either the parent company or local entity level. However, at times materials and information required in the documentation package (master file, local file...
- TPG2022 Chapter V paragraph 5.32Not all transactions that occur between associated enterprises are sufficiently material to require full documentation in the local file. Tax administrations have an interest in seeing the most important information while at the same time they also have an interest in seeing that...
- TPG2022 Chapter V paragraph 5.51It is recommended that all MNE groups be required to file the Country-by-Country Report each year except as follows....
- TPG2022 Chapter V paragraph 5.62Jurisdictions endeavour to introduce as necessary domestic legislation in a timely manner. They are also encouraged to expand the coverage of their international agreements for exchange of information. The implementation of the package will be monitored on an ongoing basis. The outcomes of...
- TPG2022 Chapter V paragraph 5.24The Country-by-Country Report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE group operates. The report also requires a listing...
- TPG2022 Chapter V paragraph 5.22In contrast to the master file, which provides a high-level overview as described in paragraph 5.18, the local file provides more detailed information relating to specific intercompany transactions. The information required in the local file supplements the master file and helps to meet...
- A Toolkit on the Taxation of Offshore Indirect TransfersThe Platform for Collaboration on Tax (IMF, OECD, UN and the WBG) has published a toolkit on the taxation of Offshore Indirect Transfers. The tax treatment of ‘offshore indirect transfers’ (OITs) – in essence, the sale of an entity owning an asset located...
- Guidance on the attribution of profits to permanent establishments 2008On 17 July 2008, the OECD Council approved the release the Report on the Attribution of Profits to Permanent Establishments. The Report includes a preface and four Parts. Part I sets out general considerations for attributing profits to permanent establishments, regardless of the...
Related Case Law
- Denmark vs Tetra Pak Processing Systems A/S, April 2021, Supreme Court, Case No BS-19502/2020-HJRThe Danish tax authorities had issued a discretionary assessment of the taxable income of Tetra Pak Processing Systems A/S due to inadequate transfer pricing documentation and continuous losses. Judgement of the Supreme Court The Supreme Court found that the TP documentation provided by...
- Mexico vs “TP doc-Lawsuit”, June 2019, Supreme Court, Case No. 14039/17-17-10-3/2502/18-PL-07-04In this case a group of taxpayers filed a lawsuit for the nullity of the new Mexican transfer pricing documentation obligations introduced in 2017 by rules 3.9.11, 3.9.14, 3.9.15, 3.9.16 and 3.9.17 of the First Resolution of Amendments to the Tax Miscellaneous published...