OECD Releases Draft of Radical Country-by-Country Reporting Template

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The OECD has just published its draft of “A Model Template of Country-by-Country Reporting” that would require companies for the first time to provide tax administrations with exhaustive details of how they allocate their income, taxes, and business activities on a country-by-country basis.

On July 19, 2013 BEPS Action Plan, the OECD was directed to “develop rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into account the compliance costs for business.

The rules to be developed will include a requirement that MNE’s provide all relevant governments with needed information on their global allocation of the income, economic activity and taxes paid among countries according to a common template”.

This paper contains an initial draft of revised guidance on transfer pricing documentation and country by country reporting. It is submitted for comment by interested parties.

The draft template, which is subject to comments and a public consultation, requires a company for each country in which it operates to list their “constituent entities,” effective place of management, and important business activities.

In addition, the draft template would also require a company to report on a country-by-country basis:

• its revenues,
• earnings before income tax,
• income tax paid on a cash basis to the country of organization and to all other countries,
• total withholding tax paid,
• stated capital and accumulated earnings,
• number of employees,
• total employee expense,
• tangible assets other than cash and cash equivalents,
• royalties paid to constituent entities,
• royalties received from constituent entities,
• interest paid to constituent entities,
• interest received from constituent entities,
• service fees paid to constituent entities, and
• service fees received from constituent entities.

In accordance with Circular 230 Disclosure

Mr. Marini concentrates his practice in Representation before the IRS and All Other Tax Authorities, IRS Collections, Offers in Compromise, Installment Payment Plans, Appeals, Sales Tax Audits, International and Tax Law, Asset Protection and Estate Planning.

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