In 2013, to address the rising global challenge of base erosion and profit shifting (BEPS), countries in the Organisation for Economic Co-Operation and Development (OECD) and the G20 adopted a 15-point action plan aimed at neutralising BEPS strategies, improving transparency and aligning taxation with substance. The report on one of those actions, Transfer Pricing Documentation and Country-by-Country Reporting: Action 13 Final Report (the “BEPS Action 13 report”), was issued in October 2015. The BEPS Action 13 report recommended that large multinational enterprises (MNEs) with turnover of €750m or more should annually prepare a country-by-country (CbC) report, to include aggregated data on the global allocation of income, profit, taxes paid and economic activity among the tax jurisdictions in which they operate.
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