Country by country reporting

Abstract

The three pillar approach to transfer pricing documentation makes multinational enterprises obliged to provide in master file, local file and country by country report the consistent transfer pricing positions that enable tax authorities to assess whether companies have engaged in transfer pricing practices that have the effect of artificially shifting substantial amounts of income into a tax-advantaged environment. The main goal of this contribution is to clarify the tool of country by country reporting and mention the potential issues of its implementation process.