The OECD has published a memorandum on the development of a country-by-country reporting template as part of the BEPS action plan. Country-by-country reporting to governments will be ‘an essential element’ of transfer pricing documentation proposals that will be the subject of a public consultation on 12–13 November.
The memorandum sets out a number of questions that would need to be resolved, and notes that ‘consideration should be given to whether the information sharing system should be structured in a way that excludes delivery of information to countries where adequate provisions do not exist to protect the confidentiality of competitively sensitive data’.
The OECD has published a memorandum on the development of a country-by-country reporting template as part of the BEPS action plan. Country-by-country reporting to governments will be ‘an essential element’ of transfer pricing documentation proposals that will be the subject of a public consultation on 12–13 November.
The memorandum sets out a number of questions that would need to be resolved, and notes that ‘consideration should be given to whether the information sharing system should be structured in a way that excludes delivery of information to countries where adequate provisions do not exist to protect the confidentiality of competitively sensitive data’.