OECD’s New Country-By-Country Transfer Pricing Reporting Template

On January 30, 2014, the Organization for Economic Cooperation and Development (OECD) released a discussion draft for comment on Action 13; the transfer pricing documentation prong of the Base Erosion and Profit Shifting (BEPS) project, which includes country-by-country reporting. As the Committee of Fiscal Affairs believes it is essential to obtain input from stakeholders on this Discussion Draft to advance work, MNP LLP and its international affiliate firms (Praxity) put forth comments addressing specific issues identified in the Discussion Draft.

Action 13 of the BEPS project grew out of the OECD project on simplifying transfer pricing documentation that culminated in the July 2013 white paper on transfer pricing documentation. As transfer pricing has grown in importance over recent years, the business community has been confronted with an immense proliferation of documentation requirements that has resulted in a large compliance burden.