It is the intention of the countries participating in the OECD/G20 BEPS Project to reconsider the appropriateness of the applicable revenue threshold described in the preceding paragraph in connection with their 2020 review of implementation of the new standard, including whether additional or different data should be reported.
TPG2017 Chapter V paragraph 5.54
Category: E. Implementation, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter V: Documentation | Tag: Implementation of CbC reporting, Transfer pricing documentation
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- TPG2022 Chapter V paragraph 5.55It is considered that no exemptions from filing the Country-by- Country Report should be adopted apart from the exemptions outlined in this section. In particular, no special industry exemptions should be provided, no general exemption for investment funds should be provided, and no...
- TPG2022 Chapter V paragraph 5.54It is the intention of the countries participating in the OECD/G20 BEPS Project to reconsider the appropriateness of the applicable revenue threshold described in the preceding paragraph in connection with their 2020 review of implementation of the new standard, including whether additional or...
- TPG2022 Chapter VII paragraph 7.64An MNE group electing for application of this simplified methodology shall prepare the following information and documentation and make it available upon request to the tax administration of any entity within the group either making or receiving a payment for low value-adding intra-group...
- TPG2022 Chapter V paragraph 5.53It is believed that the exemption described in paragraph 52, which provides a threshold of EUR 750 million, will exclude approximately 85 to 90% of MNE groups from the requirement to file the Country-by-Country Report, but that the Country-by-Country Report will nevertheless be...
- 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 5.60Jurisdictions should require in a timely manner Country-by-Country Reporting from ultimate parent entities of MNE groups resident in their jurisdiction and referred to in Section E.2.2 and exchange this information on an automatic basis with the jurisdictions in which the MNE group operates...
- 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 5.49It is recommended that the master file and local file elements of the transfer pricing documentation standard be implemented in each jurisdiction through local legislation or administrative procedures and that the master file and local file be filed directly with the tax administrations...
- OECD’s Manual on Exchange of Information and on Conducting Simultaneous Tax ExaminationsThe purpose of the Manual is to provide tax officials dealing with exchange of information for tax purposes with an overview of the operation of exchange of information provisions and some technical and practical guidance to improve the efficiency of such exchanges. The...
- A Toolkit on Tax Treaty NegotiationsThe Platform for Collaboration on Tax (IMF, OECD, UN and the WBG) has published a toolkit on Tax Treaty Negotiations. The Toolkit represents a joint effort to provide capacity-building support to developing countries on tax treaty negotiation, building on previous contributions and reducing...
Related Case Law
- Greece vs “Diary Distributor Ltd.”, November 2021, Tax Court, Case No 579/2021This case deals with arm’s length remuneration of a Greek Diary Distributor. Following an audit of “Diary Distributor Ltd.”, the Greek tax authorities determined that the prices paid to related parties for FY 2017 had been above the arm’s length price. On that...
- Denmark vs. Adecco A/S, June 2020, Supreme Court, Case No SKM2020.303.HRThe question in this case was whether royalty payments from a loss making Danish subsidiary Adecco A/S (H1 A/S in the decision) to its Swiss parent company Adecco SA (G1 SA in the decision – an international provider of temporary and permanent employment...
- 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...
- Denmark vs. Software A/S, September 2020, Tax Court, Case no SKM2020.387.LSRSoftware A/S was a fully fledged Danish distributor of software an related services up until 2010 where the company was converted into a commissionaire dealing on behalf of a newly established sales and marketing hub in Switzerland. Following an audit, the Danish tax...