Transfer pricing documentation and country by country reporting

In days past transfer pricing documentation and all that it entails rarely made headlines or warranted detailed discussion amongst taxpayers and advisers. Documentation was simply yet another (thankless) compliance task that the overburdened transfer pricing department had to manage. However when the OECD published its 15 point Action Plan for BEPS in July 2013 it was clear that the importance and relevance of transfer pricing documentation had multiplied considerably. The words ‘Action 13’ were soon to be repeated in tax departments of multinational enterprises (MNEs) across the globe.

The discussion that follows provides an overview of Action 13 (Transfer pricing documentation and country by country reporting) the potential impact on MNEs and how the OECD recommendations may be implemented...