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Transfer Pricing

Action 13: Transfer Pricing Documentation and Country by - Country Reporting

CbC report contains financial information pertaining to global allocations of revenue, profit, taxes, etc. within the members of large multinational groups spread across various tax jurisdictions. It aims at empowering the tax authorities to conduct robust and effective risk assessments. The said information is to be exchanged between jurisdictions where the multinational group has taxable presence.

Our publication “Action 13: Transfer Pricing Documentation and Country-by-Country Reporting – Outlook Paper” discusses the proposed change, its genesis, global developments, and its impact. Following are the key highlights of this report are:

  • Brief background of G-20 and OECD’s BEPS initiative;
  • Overview of OECD’s final report on Action 13;
  • Snapshot of the Budget 2016’s proposal made with regard to new documentation requirements;
  • Summary of the global developments on implementation of CbC reporting;
  • Quick review of the possible impact of CbC reporting on India; and

Preliminary recommendations to prepare large multinationals for the change.