Transfer Pricing: Country by Country Reporting Requirements

As part of the Action 13 report of the OECD and G20’s BEPS (Base Erosion and Profit Shifting) initiative, a number of tax authorities have agreed to increase tax transparency to address the BEPS problem. 

The Action 13 report made three recommendations, two of which relate to transfer pricing documentation, the third is the introduction of Country by Country (CbyC) reporting.

In implementing this, the UK tax authorities have introduced a new statutory requirement for large Multinational Enterprises (MNEs) with a UK presence to file an annual CbyC report.