handbook-tb

Transparency and disclosureenhancement of transparency for tax administration, and sensitivityto taxpayer compliance costs. But perhaps more importantly, Action13 seeks the establishment of rules that would require an MNE to “provideall relevant governments with needed information on their globalallocation of the income, economic activity and taxes paid amongcountries according to a common template.” 17 This reporting templateconcept is known as “country-by-country reporting.”The prospect of a new reporting format with new informationraised a number of questions that have dominated the discussion ofCbC reporting. Briefly, the issues can be broadly identified as: (a) thekind of information required; (b) the burden on taxpayers; (c) thepermitted recipients of the information; (d) the permitted uses of theinformation; (e) the ability of a country to use the information; (f) theprotection of taxpayer data; and (g) the delivery mechanism. 183.3.2 OECD introduction of Action 13In January 2014 the OECD released a Discussion Draft on TransferPricing Documentation and CbC Reporting (Discussion Draft). 19 Itidentified the three core goals for transfer pricing documentation:(a) risk assessment: “to provide tax administrations with the informationnecessary to conduct an informed transfer pricing risk assessment”;(b) appropriate taxpayer pricing practices: “to ensure thattaxpayers give appropriate attention to transfer pricing requirementsin establishing prices and other conditions for transactions betweenassociated enterprises and in reporting the income derived from suchtransactions in their tax returns”; and (c) audit support: “to providetax administrations with the information that they require in order to17Ibid.18See, for example, OECD, Memorandum on Transfer Pricing Documentationand Country by Country Reporting (3 October 2013), available at http://www.oecd.org/ctp/transfer-pricing/memorandum-transfer-pricing-documentation-and-country-by-country-reporting.pdf.19OECD, Public Consultation: Discussion Draft on Transfer Pricing Documentationand CbC Reporting (30 January 2014), available at http://www.oecd.org/ctp/transfer-pricing/discussion-draft-transfer-pricing-documentation.pdf.511