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Author: C. Silberztein Publisher: ISBN: Category : Languages : en Pages : 86
Book Description
On 29 September 2017, the OECD released "Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment", which provides tax authorities with guidance on ways to incorporate information obtained under CbC reporting into their tax risk assessment processes, the types of tax risk indicators that may be identified using CbC reports, and the challenges that may arise in the process. In this article, the authors outline the key elements provided in this report, illustrate with a practical example how tax authorities may use CbC reporting information to supplement their existing tax risk assessment and discuss the consequences thereof.
Author: C. Silberztein Publisher: ISBN: Category : Languages : en Pages : 86
Book Description
On 29 September 2017, the OECD released "Country-by-Country Reporting: Handbook on Effective Tax Risk Assessment", which provides tax authorities with guidance on ways to incorporate information obtained under CbC reporting into their tax risk assessment processes, the types of tax risk indicators that may be identified using CbC reports, and the challenges that may arise in the process. In this article, the authors outline the key elements provided in this report, illustrate with a practical example how tax authorities may use CbC reporting information to supplement their existing tax risk assessment and discuss the consequences thereof.
Author: Publisher: ISBN: Category : Languages : en Pages :
Book Description
QUESTIONS: The country-by-country information in the proposed master file is intended to be helpful in risk assessment processes, and is a response to the OECD's July 19, 2013, Base Erosion and Profit Shifting (BEPS) Action Plan for the development of rules to enhance transparency for tax administration. It is intended that it should facilitate the application of the OECD's (Draft) Handbook on Transfer Pricing Risk Assessment of April 30, 2013; To what extent has your tax authority indicated that it would make use of the full list of information that is required by the template in transfer pricing risk assessments?; To what extent is it already asking for and making use of this information? The information specified in the country-by-country reporting template overlaps with the factors which are often used to apply the OECD's Profit Split Method (in line with paragraph 2.135 of the OECD's Transfer Pricing Guidelines); To what extent have your local tax authority or your local courts shown a willingness or preference to use the Profit Split Method? The information specified in the country-by-country reporting template overlaps with the factors (sales, tangibles assets, employees, payroll) proposed for use in the European Commission's Common Consolidated Corporate Tax Base (see COM(2011)121/4); To what extent have your tax authority or your local courts been prepared to adopt a global formulary apportionment of profit as opposed to following the arm's length principle set forth in Article 9 of the OECD Model Tax Convention?
Author: S. Picariello Publisher: ISBN: Category : Languages : en Pages :
Book Description
This article provides some considerations on the use of the country-by-country reporting for tax risk assessment through an in-depth review of the potential issues associated with the implementation, design and appropriate use of the country-by-country report. After providing a broader conceptual framework that outlines the general benefits of incorporating the report into a tax authority's risk assessment framework, the article specifically suggests potential areas for improvement in respect of how to address the different issues and examines whether modifications should be made to the standard, especially in light of the forthcoming 2020 review. Such recommendations are addressed to tax administrations and multinational enterprise groups, since inefficient use will be burdensome for both parties. The analysis also takes into consideration the recent public consultation draft issued by the OECD.
Author: OECD Publisher: ISBN: 9789264474635 Category : Languages : en Pages : 566
Book Description
Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity. This unprecedented information on MNE Groups' operations across the world will boost tax authorities' risk-assessment capabilities. The Action 13 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review process. The peer review of the Action 13 Minimum Standard is proceeding in stages with three annual reviews in 2017, 2018 and 2019. The phased review process follows the phased implementation of CbC Reporting. Each annual peer review process will therefore focus on different aspects of the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. This second annual peer review report reflects the outcome of the second review which considered all aspects of implementation. It contains the review of 116 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.
Author: D. Ernick Publisher: ISBN: Category : Languages : en Pages :
Book Description
This article assesses the OECD's country-by-country reporting risk assessment handbook. The author says the use of simple quotients by tax authorities to determine transfer pricing risk, as the handbook advocates, is antithetical to the facts and circumstances analysis required in a transfer pricing system based on the arm's-length principle.
Author: Organisation for Economic Co-operation and Development Publisher: ISBN: 9789264300972 Category : Languages : en Pages : 870
Book Description
Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity. This unprecedented information on MNE Groups' operations across the world will boost tax authorities' risk-assessment capabilities. The Action 13 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review process. The peer review of the Action 13 Minimum Standard is proceeding in stages with three annual reviews in 2017, 2018 and 2019. The phased review process follows the phased implementation of Country-by-Country (CbC) Reporting. Each annual peer review process will therefore focus on different aspects of the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. This first annual peer review report reflects the outcome of the first review which focused on the domestic legal and administrative framework. It contains the review of 95 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.
Author: T.X. Pèrez Salazar Publisher: ISBN: Category : Languages : en Pages : 50
Book Description
The main objective of this thesis is to analyse the limitations and advantages of the country-by-country reporting (CbCR) included in Action 13 of the BEPS Action Plan as a tool for BEPS risk asessment, for which this research has the following secondary objectives: review what was the problem with the transfer pricing regime regarding the lack of transparency and low taxation before the existence of the BEPS Action Plan; examine the generalities included in Action 13 of the BEPS Action Plan and what is the three-tiered approach suggested by the OECD regarding transfer pricing documentation; study how the risk assessment can be carried out through the CbCR; analyse through case studies the impact of the CbCR on the risk assessment by the tax authorities. The author finally issues conclusions and recommendations.
Author: P. Klaassen Publisher: ISBN: Category : Languages : en Pages :
Book Description
A low effective tax rate in combination with a high profit can be an important indicator of possible tax avoidance. This article discusses the limitations of the definitions of two columns in the country-by-country report, namely 'profit (loss) before income tax' and 'income tax accrued - current year'. The authors conclude that the effective tax rate calculated based on the country-by-country report can not be accurately used in high level risk analyses.
Author: Michael Lang Publisher: Kluwer Law International B.V. ISBN: 904119021X Category : Law Languages : en Pages : 500
Book Description
Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Author: C. Silberztein
Author: C. Silberztein
Author: 
Author: S. Picariello
Author: Oecd
Author: OECD
Author: D. Ernick
Author: Organisation for Economic Co-operation and Development
Author: T.X. Pèrez Salazar
Author: P. Klaassen
Author: Michael Lang