Implementation status: OECD Master File concept and CbC-Reporting

Published on June 12, 2019


The public’s focus surrounding international tax matters has increased consistently in recent years and has never been stronger than its current state. The Base Erosion and Profit Shifting (“BEPS”) Project was initiated by the OECD and G20 to combat perceived profit shifting activities and represents an organized effort to establish an effective framework to deal with ever-increasing global tax challenges.


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One of the BEPS Action Points enhanced taxpayer transparency for tax administrations by requiring Multinational Enterprises (“MNEs”) to report information on a country-by-country basis relevant to the risk assessment and examination of the underlying TP documentation (“BEPS Action 13: Re-examine Transfer Pricing Documentation”). The final report (“Action 13: 2015 Final Report - Transfer Pricing Documentation and Country-by-Country Reporting”) was published on 5 October 2015 by the OECD and contains guidance on Transfer Pricing Documentation and CbC-Reporting. In July 2017, this report completely replaced Chapter 5 of the OECD’s Transfer Pricing Guidelines.

For more information on the status of implementation with respect to single jurisdictions, the international TP Group of Rödl & Partner has generated an overview of the implementation status pertaining the OECD Master File and CbC-Reporting concept in more than 50 countries.


OECD Master File-concept and CbC-Reporting – international documentation requirements



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