Strategizing Multinational Tax Risks

The Tax Executives Institute (TEI) has commented on the OECD Transfer Pricing Documentation and Country by Country Reporting (CbC) discussion draft.

Click to access OECD%20Transfer%20Pricing%20Documentation%20and%20CbC%20Reporting.pdf

TEI has provided strategic and logical arguments in response to requested comments by the OECD for transfer pricing documentation and CbC reporting.  One of the exemplary comments put forth is that the CbC reporting template should be the last item for completion, based upon actions of the other items, to achieve maximum efficiency, relevance and avoidance of duplication in work efforts.

The TEI comments should be read by all multinationals and interested parties to further understand the business rationale and inherent complexity of the OECD proposal that may lead tax authorities to deviate from the arm’s length principle based solely on the CbC information provided.