UK Transfer Pricing legislation provides that it is to be interpreted “in such manner as best secures consistency" with a specific version of the OECD Guidelines. Until now this was the 2010 version as amended by the OECD’s final Base Erosion and Profit-Shifting (BEPS) Report of October 2015.
There have been dramatic improvements in tax transparency over the past decade. However, challenges still remain. High profile leaks, such as the release of the 'Panama' and the 'Paradise' papers by the International Consortium of Investigative Journalists (ICIJ), underscore the widespread use of offshore structures to hide beneficial ownership of assets and income.
Country by Country Reporting (CbCR) is more than just another compliance burden. Knowing how to interpret the technical rules and making sure 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 view and respond to the data you are providing, and determining how clients will access the required data, are all crucial.
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.
UK headquartered groups caught by Country by Country Reporting (CbCR) rules with December year ends, the deadline for their first submission is 31 December 2017. The report must be made in the form of an XML document. You cannot submit a pdf or alternative file format. PwC's service takes your excel or word CbC report and with limited additional effort from you converts the information into an XML format ready for submission.