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2017 Transfer Pricing Deadlines

As we approach the end of the year, here are a couple deadlines to be aware of: Country-by-Country Reporting Notification For U.S. ultimate parent entities of multinational enterprises (“MNEs”) that are filing Internal Revenue Service Form 8975 and Schedules A (Form 8975) (“Country-by-Country Report”) for the year ending December 31, 2017, the Country-by-Country Report will [...]

By | 2017-12-14T19:37:34+00:00 December 14th, 2017|

OECD Recent Handbook on CbC Reporting

The OECD recently released CbC Reporting – Handbook on Effective Tax Risk Assessment.  This guidance is designed to help tax authorities develop an effective approach for using the data contained in the CbC report to assess which taxpayers pose the most – or least – risk from a tax authority perspective.  In addition, this guidance [...]

By | 2017-11-13T01:06:03+00:00 November 8th, 2017|

3 Ways CbC Data Can Be Misinterpreted

Now that the tax return deadline for U.S. multinationals on a calendar year has come and gone, and the first batch of country-by-country (CbC) reports have been filed, many taxpayers are now taking the opportunity to reflect on exactly how CbC data can be interpreted by tax authorities and what the next steps are. Data [...]

By | 2017-11-13T01:06:43+00:00 October 24th, 2017|

Updated Guidance on Implementation of Country-by-Country Reporting

The Organisation for Economic Co-operation and Development (“OECD”) issued updated guidance (“Guidance”) on the implementation of country-by-country reporting (“CbC”) in September 2017.  The Guidance adds certain items to the version issued in July 2017.  The new items are: DEFINITION OF REVENUES. The Guidance provides that “all revenue, gains, income, or other inflows shown in the financial [...]

By | 2017-11-13T01:06:58+00:00 October 16th, 2017|