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BEPS Action 13: Country-by-country Reporting Implementation Package
Tax Analysis:June 26, 2015/China
On 8 June 2015, the OECD, as part of the G20/OECD work on the action plan to address base erosion and profit shifting (BEPS), released Action 13: Country-by Country Reporting Implementation Package. (Tax Analysis:June 26, 2015/China)
This follows the two reports previously issued by the OECD: (i) the agreement of a three-tier global standard for transfer pricing documentation, including a common template for county-by-country (CbC) information to be reported to the tax authorities (released in September 2014); and (ii) implementation guidance in relation to the CbC report, including the timing of introduction, application to “large” businesses and filing mechanisms (released in February 2015). The implementation package outlines model legislation that governments can use to adopt the new rules, as well as competent authority agreements to implement the sharing mechanisms for the CbC report.
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