First published in BNA Bloomberg Tax Planning International, 30 July 2016.
Under BEPS, the global tax landscape for multinational companies is subject to fundamental reform, the principles of which have been substantially agreed by over 60 OECD Member States.
One of the fundamental pillars of the BEPS project is to ensure that the global activities of companies are more transparent to tax authorities worldwide.
At this stage, the OECD has reached agreement on the framework for transparency measures and has published its recommendations in Action 13 (Transfer Pricing Documentation and Country-by-Country reporting). The focus now is on implementing these principles into domestic legislation.
The EU has also been playing a key role in ensuring a coordinated and consistent approach is taken with regard to the implementation of BEPS across the EU Member States.
This article focuses on Action 13 and looks at the EU drive towards greater tax transparency as a result of the published OECD guidelines and recommendations.
All in all, one would welcome Europe’s proactive approach to Action 13. However, with the potential introduction of Public CbCR and the relaunch of the CCTB one would hope that such measures in Europe do not dampen Europe’s attractiveness as a location in which to do business.