People who regularly visit our section CALENDARS might already have noticed that in our Calendar for January 25 – January 31, 2016 we mention the Signing ceremony with respect to a Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports that is supposed to take place on January 27, 2016.
We have not seen an official announcement by the OECD, but from a press release issued earlier this week by the Swiss Government we understand that on January 27, 2016 there will be a signing ceremony with respect to a Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports.
According to this press release “Numerous states and territories, including Switzerland, will sign the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports in Paris on 27 January 2016.”
On October 5, 2015 the OECD published its 2015 deliverables. One of the deliverables published was the Final report on Action 13 - Transfer Pricing Documentation and Country‑by‑Country Reporting, a link to which you can find in our Section BEPS LIBRARY.
Under this action the OECD recommends a.o. that large MNEs are required to file a Country-by-Country Report that will provide annually and for each tax jurisdiction in which they do business the amount of revenue, profit before income tax and income tax paid and accrued. It also requires MNEs to report their number of employees, stated capital, retained earnings and tangible assets in each tax jurisdiction. Finally, it requires MNEs to identify each entity within the group doing business in a particular tax jurisdiction and to provide an indication of the business activities each entity engages in.
In order to facilitate the implementation of the new reporting standards, the OECD developed an implementation package consisting of model legislation which could be used by countries to require MNE groups to file the Country-by-Country Report and competent authority agreements that are to be used to facilitate implementation of the exchange of those reports among tax administrations.
One of these model legislation is the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports. A draft of which can be found on page 45 of the Final report on BEPS Action 13. As we understand from the press release issued by the Swiss Government it is this Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports that will be signed in Paris by Switzerland and numerous other states on January 27, 2016.
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