The Country-by-Country Report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE group operates. The report also requires a listing of all the Constituent Entities for which financial information is reported, including the tax jurisdiction of incorporation, where different from the tax jurisdiction of residence, as well as the nature of the main business activities carried out by that Constituent Entity.
TPG2017 Chapter V paragraph 5.24
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Country-by-Country Reporting, Transfer pricing documentation
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