OECD releases memorandum on transfer pricing documentation and country-by-country reporting

Tax Controversy & Dispute Resolution ()

On October 3, 2013, the OECD released a memorandum on transfer pricing documentation and country-by-country reporting (the “Memorandum”). The Memorandum concerns the implementation issues to be addressed in developing a country-by-country reporting template as part of Action 13 of the BEPS Action Plan and raises two key questions for discussion at the OECD public consultation on various transfer pricing issues on November 12–13, 2013:

  • What information should be required in the country-by-country report template; and
  • What mechanisms should be developed for reporting and sharing country-by-country data?