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Diane RingBusiness organizations, in contrast, strongly urge careful protectionof taxpayer data and reject the idea that public disclosure ofsome of the Action 13 information (such as the CbC report) couldbe an appropriate response. The Business and Industry AdvisoryCommittee to the OECD (BIAC) contended that the master file andthe CbC report “should only be provided by taxpayers to their home(headquarter) tax administrations, to then be shared through existingexchange of information channels with the necessary confidentialityrequirements.” 29 Rather than contemplate some form of limitedpublic disclosure, BIAC sought enhanced measures to safeguard taxpayerinformation (including “anti-infringement procedures” to protecttaxpayers from unauthorized disclosure, the viewing of certaininformation only at the taxpayer site, and legally binding confidentialityagreements between taxpayers and tax administrations). 30 TheInternational Alliance for Principled Taxation similarly recommendedthat “the CbC report be filed with the parent company’s home countrytax authority as the Discussion Draft contemplates, but that it then beshared with other tax authorities only through a formal EOI channel(whether spontaneously or upon request), so that confidentialityobligations will apply to the recipient governments.” 31 In addition tothe concerns about the public disclosure of trade secrets and relatedinformation, multinationals and their representatives have expressedconcern that public disclosure of tax information could easily be misinterpretedand used (inappropriately) for political purposes.The OECD has repeatedly asserted that the Action 13 informationis intended only for governments and only for the purposes ofmaking risk assessments for BEPS. Given the importance of this issueinclude reporting on a single ratio between tax charge and declared profitsto give some indication on the potential presence of risk for transfer pricingmanipulation and other aggressive tax planning schemes.”29BIAC, OECD Discussion Draft on Transfer Pricing Documentation(“TPD)” and Country by Country (“CbC”) Reporting (21 February 2014),available at http://www.oecd.org/ctp/transfer-pricing/volume1.pdf.30Ibid.31International Alliance for Principled Taxation, Comments on DiscussionDraft on Transfer Pricing Documentation and CbC Reporting (23 February2014), available at http://www.oecd.org/ctp/transfer-pricing/volume2.pdf.528

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