Tax Dispute Resolution Quarterly

Country by country, step by step:
Implementation considerations for country-bycountry
reporting by U.S. multinationals
By Thomas Herr, Raj Bodapati, and Rui Che, Economic and Valuation
Services
While the Organisation for Economic Co-operation and Development’s (OECD)
project to combat tax base erosion and profit shifting (BEPS) had an ambitious
agenda, the verdict on whether it will meet all its objectives remains uncertain.
However, one very tangible impact for large multinational enterprises is clear:
The requirement to file annual country-by-country reports.
The authors of an article in the April 14 edition of Tax Management Transfer
Pricing Report outline considerations for U.S. multinationals preparing to embark
on country-by-country reporting as set forth in the final recommendations under
the OECD’s project to combat BEPS, focusing on establishing a process for
preparing the report, as well as analysis of the data necessary to ensure overall
consistency in transfer pricing and other tax positions.
2x4 approach to country-by-country reporting
By Kim Majure, Washington National Tax, and Steven Penning,
International Tax
Many multinational enterprise groups are already working to implement
new annual reporting requirements—country-by-country (CbyC) reporting—
promulgated the U.S. Treasury Department. Proposed regulations that would
require certain taxpayers with annual revenue of $850 million or more to file this
report are expected to be finalized later in 2016. The proposed U.S. regulations
were developed in response to the guidelines issued by the Organisation for
Economic Co-operation and Development as part of its base erosion and profit
shifting initiative.
An April 27, 2016 KPMG LLP report organizes the considerations for developing a
practical approach to CbyC reporting into two main areas—tax data management
and tax data and analytics—each with four steps.
Post-BEPS world of permanent establishment
By Kevin Cunningham, Washington National Tax
In this May 2 article in Tax Notes International, the author discusses how
the Organisation for Economic Co-operation and Development’s final base
erosion and profit-shifting report on action 7 (artificial avoidance of permanent
establishment status) would change the definition of permanent establishment
and the effect that change could have on multinational enterprises.
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