Source: Deloitte Global Transfer Pricing Alert, 1st July 2016
The OECD on June 29, 2016, issued additional guidance on the implementation of the country-by-country (CbC) reporting requirement introduced in the BEPS Action 13 Final Report issued on October 5, 2015.
The guidance covers four issues:
- Transitional filing options to eliminate initial year effective dates differences (the “gap” year issue)
- The application of CbC reporting to investment funds
- The application of CbC reporting to partnerships
- The impact of currency fluctuations on the EUR 750 million filing threshold