USA Getting Onboard BEPS CbC Reporting

By Robert Robillard - 9 March 2015

This blogpost originally appeared on rbrt.ca.

Full credit goes to BNA Bloomberg Transfer Pricing Report.

According to BNA Bloomberg Transfer Pricing Report (excerpts available on Linkedin; used with permission), the USA are expected to implement the OECD country-by-country (CbC) reporting template.

On September 16, 2014, the OECD released Guidance on Transfer Pricing Documentation and Country-by-Country Reporting.

It was followed by Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting on February 6, 2015.

Both documents are available here.

The CbC reporting template is a cornerstone of action 13 of the OECD BEPS Action plan which pertains to transfer pricing documentation.

Paragraph 7 of the Guidance on the implementation suggest that “the first CbC Reports be required to be filed for MNE fiscal years beginning on or after 1 January 2016.” However, “given the recommendation in the September Report that MNEs be allowed one year from the close of the fiscal year to which the CbC Report relates to prepare and file the CbC Report, this recommendation means that the first CbC Reports would be filed by 31 December 2017.”

Paragraph 9 states that “groups with annual consolidated group revenue in the immediately preceding fiscal year of less than € 750 million or a near equivalent amount in domestic currency […] would not be required to file the CbC Report in any country […]”.

With France, the UK, and Spain already onboard, the addition of the USA clearly signals that the time for any company involved in international transactions to review its transfer pricing policies and procedures has now more than ever arrived.

Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Inc.
514-742-8086; robertrobillard “at” rbrt.ca
www.rbrt.ca

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