Introduction of requirements for the preparation of three-tier transfer pricing documentation in accordance with a BEPS plan

In October 2015, the Organisation for Economic Cooperation and Development (“OECD”), with the assistance of the Group of Twenty (“G20”) countries, published a series of final reports within the framework of actions to combat Base Erosion and Profit Shifting (“BEPS”).

Specifically, BEPS action No. 13 proposed the concept of three-tier transfer pricing documentation, which involves multinationals preparing a Master File, Local File and Country-by-Country Reporting (“CbCR”).

The concept reflects G20 and OECD intentions to introduce an integrated international standard for reporting on transfer pricing and implement it in those countries.

The expectation is that the business community will welcome the uniformity, as it will help reduce costs incurred ensuring compliance with local statutory requirements.

More than 20 the preparation and filing of the documentation in question.

In those countries where amendments have already been adopted (for example, the Netherlands, Spain and the UK), the first reporting period for CbCR will be 2016.

Although Kazakhstan is not an OECD member and has no CbCR and Master File preparation and filing requirements, local companies will be obliged to prepare the documentation if certain conditions are met (see the details below).

countries have already amended national legislation (or prepared draft amendments) around