Taxand Netherlands and Taxand USA examines the arrangement of exchanging Country-by-Country reports between the Netherlands and the United States.
Within the framework of Action 13 of the OECD/G20 Action Plan to tackle tax Base Erosion and Profit Shifting, the Netherlands and the USA have entered into a Competent Authority Arrangement (the Arrangement) enabling the automatic Exchange of Country-by-Country Reports (CbCRs) between the countries.
Multinational enterprises (MNEs) will have to file a CbCR in the countries where they are active and that have implemented CbCR legislation. The information to be included in a CbCR generally encompasses a list of the MNE group’s business units (the Reporting Entity itself and so called Constituent Entities including both entities and permanent establishments worldwide), financial information such as revenues, profits, income taxes accrued and paid, stated capital, accumulated earnings and tangible assets, and employee information per tax jurisdiction.
Taxpayers should review their transfer pricing policy in accordance with the latest applicable transfer pricing guidelines and should timely possess the appropriate and updated documentation to substantiate the transfer prices applied in related party transactions.