Transfer Pricing Documentation and Country-by-Country Reporting
Many countries recently introduced, or are in the course of introducing, more specific transfer pricing documentation requirements for Multinational Enterprises. These include the requirement to prepare and file a Country-by-Country Report. These requirements largely follow the recommendations of the OECD, issued in the 2015 Final Report on Action 13, which outlines a three-tiered approach to transfer pricing documentation. Several countries have implemented according regulations that will be applicable already as of FY 2016. Many others have announced that they will implement the recommendations effectively as of 2017 or shortly thereafter.