9 January 2017

TRANSFER PRICING, SOME POST BEPS NUMBERS COUNTRY BY COUNTRY REPORTING AND ITS BIG IMPACT

As we already know, Action #13 from BEPS requires that many Multinational Groups (MG) to filing the Country by Country reporting (CbC) for fiscal years beginning on or after January 1st, 2016.

At a first glance, we may believe that this new compliance rule may have only impact on the big MG (those with revenues above 750 million euros per year), however, we may bear in mind that the information required includes sensitive tax information about all subsidiaries.

In this sense, we want to share with you some numbers that comes from a recent survey carried out by the Consultancy Firm Thompson Reuter. It shows very interesting trends regarding different BEPS actions. To the question about which action presents the biggest change on the Tax departments, the outcomes were as follows:

It is not a surprise that the CbC reporting is the major concern among MG because, if we carefully review the information that must be submitted, we realize that such report stands for an invaluable tool for tax authorities in terms of a better tax scrutiny.

In line with this, 42% of the MG pointed out that to be subject of an auditing process is their biggest concern right now.

Furthermore, in the las 5 years the number of countries that have introduce transfer pricing regulations have doubled and reaching a total of 101 worldwide countries so far.

There is no doubt that CbC reporting will be the main tax topic in the next months and even more as the first “dead line” gets closer.

Miguel Rodríguez, Auren México

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