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OECD issues memo on development of country-by-country template

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The OECD has published a memorandum on the development of a country-by-country reporting template as part of the BEPS action plan.

The OECD has published a memorandum on the development of a country-by-country reporting template as part of the BEPS action plan. Country-by-country reporting to governments will be ‘an essential element’ of transfer pricing documentation proposals that will be the subject of a public consultation on 12–13 November.

The memorandum sets out a number of questions that would need to be resolved, and notes that ‘consideration should be given to whether the information sharing system should be structured in a way that excludes delivery of information to countries where adequate provisions do not exist to protect the confidentiality of competitively sensitive data’.

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