Jurisdictions should use their best efforts to adopt a legal requirement that MNE groups’ ultimate parent entities resident in their jurisdiction prepare and file the Country-by-Country Report, unless exempted as set out in paragraph 5.52. Jurisdictions should utilise the standard template contained in Annex III of Chapter V of these Guidelines. Stated otherwise, under this condition no jurisdiction will require that the Country-by-Country Report contain either additional information not contained in Annex III, nor will it fail to require reporting of information included in Annex III.
TPG2022 Chapter V paragraph 5.58
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter V: Transfer Pricing Documentation | Tag: Implementation of CbC reporting, Transfer pricing documentation
« Prev |
Next » TP-Guidelines
Related content:
- TPG2022 Chapter V paragraph 5.59 Jurisdictions should use appropriately the information in the Country- by-Country Report template in accordance with paragraph 5.25. In particular, jurisdictions will commit to use the Country-by-Country...
- TPG2022 Chapter V paragraph 5.50 It is recommended that the first Country-by-Country Reports be required to be filed for MNE fiscal years beginning on or after 1 January 2016. However, it...
- TPG2022 Chapter V paragraph 5.60 Jurisdictions should require in a timely manner Country-by-Country Reporting from ultimate parent entities of MNE groups resident in their jurisdiction and referred to in Section E.2.2...
- TPG2022 Chapter V paragraph 5.61 Annex IV to Chapter V of these Guidelines contains an implementation package for government-to-government exchange of Country-by-Country Reports, which includes: • Model legislation requiring the ultimate...
- TPG2022 Chapter V paragraph 5.49 It is recommended that the master file and local file elements of the transfer pricing documentation standard be implemented in each jurisdiction through local legislation or...
- TPG2022 Chapter V paragraph 5.57 Jurisdictions should have in place and enforce legal protections of the confidentiality of the reported information. Such protections would preserve the confidentiality of the Country-by-Country Report...
- TPG2022 Chapter V paragraph 5.55 It is considered that no exemptions from filing the Country-by- Country Report should be adopted apart from the exemptions outlined in this section. In particular, no...
- TPG2022 Chapter V paragraph 5.53 It is believed that the exemption described in paragraph 52, which provides a threshold of EUR 750 million, will exclude approximately 85 to 90% of MNE...
- TPG2022 Chapter V paragraph 5.52 There would be an exemption from the general filing requirement for MNE groups with annual consolidated group revenue in the immediately preceding fiscal year of less...
- TPG2022 Chapter V paragraph 5.56 The following conditions underpin the obtaining and the use of the Country-by-Country Report....