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The OECD recently issued a new handbook outlining 19 Transfer Pricing and BEPS risks and risk assessment options available to Tax Authorities to determine if multi national enterprises (MNEs) groups are exhibiting those risk. Country by Country Reporting (CbCR) is more than just another compliance burden. Knowing how to interpret the technical rules and ensuring you are meeting your filing obligations is just one aspect. Early consideration of what CbCR says about your organisation’s tax structure, how tax authorities in the UK and overseas will risk assess the MNE Group is crucial.