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Why Multinationals Need to Be Aware of New Transfer Pricing Requirements

By Tom Lickess

In 2015, the Organization for Economic Cooperation and Development (OECD) released new country-by-country reporting (CbCR) guidelines. We’ve now moved into a new reality in which CbCR and more detailed local requirements are being passed into law. As a result, many multinational enterprises (MNEs) must adhere to new, stricter reporting obligations related to their transfer pricing practices.

The new CbCR requirements being implemented by tax authorities around the world are of critical importance to MNEs. Many former and existing tax laws have more readily enabled “profit shifting” by effectively isolating tax data. Basically, tax authorities in any given country have had little to no insight into transactions between linked companies of a single multinational group, where those transactions have had no direct relevance to their own tax base. The new requirements seek to make the global operations and the financial and tax positions of multinational groups transparent to tax authorities everywhere.

In 2015, the OECD recommended that the new CbCR requirements should be implemented for fiscal years beginning on or after January 1, 2016, and should apply to MNEs with annual consolidated group revenue equal to or exceeding 750 million euros or near equivalent in domestic currency. As we’ll see, however, some countries have implemented significantly lower group revenue thresholds that multinationals and their subsidiary entities must be aware of.

Read the full blog article—including sections on documentation and filing requirements and what multinationals need to consider.



TomLickess

Tom Lickess is the Director of Radius’ International Tax advisory practice and an expert in international tax law with extensive knowledge of U.K. and Australian corporate tax rules. Prior to joining Radius, he worked at Deloitte in London and Sydney. Based in Bristol, England, Lickess is a Fellow of the Institute of Chartered Accountants and member of the Australian Mediation Association.