Country by country reporting (CbCR) is an annual filing obligation for large multinational enterprises (MNEs) under OECD BEPS Action 13. MNE groups with consolidated revenues at or above EUR 750 million must report their income, taxes paid, employees, and assets across every tax jurisdiction in which they operate. How to Comply with CbCR: Five Key
One of the many aspects of Transfer pricing (TP) compliance is adhering to the documentation requirements. As transfer pricing regulations develop the documentation requirements develop as well and become a more present part of TP compliance. The framework for those requirements is described in Chapter V of the OECD Transfer Pricing Guidelines for Multinational Enterprises
It depends. Some countries ask for the local file preparation if there are transactions, no matter the value of them, some ask only if the transaction or entity exceeds a set threshold. To understand if you need to have a local file documentation, you need to consider a few main aspects:
Global minimum tax is an OECD initiative introduced as a part of the BEPS program. The idea behind this initiative is to ensure that big multinational corporations are taxed at an effective tax rate of at least 15%. Most countries added this initiative to their local legislation. The entry into force date varies among the countries, for example, the EU has implemented the regulation from January 2024.
Amount B is a part of Pillar One from the OECD BEPS program. The purpose of Amount B is to act as a safe harbor for baseline marketing and distribution services.
Currently, the future of Amount B isn’t clear. As its implementation is optional, some countries including Germany and the Netherlands, already announced that they aren’t going to implement it.
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