The US Treasury Department has announced plans to implement a country-by-country (CbC) reporting requirement starting for fiscal years beginning in 2016 as set out in the guidance issued by the Organization for Economic Cooperation and Development on February 6, 2015.
The OECD guidance follows its September 2014 report on transfer pricing documentation. The guidance proposes a three-tiered documentation approach consisting of (1) a master file providing high-level information on the global business operations of a multinational enterprise (MNE); (2) a local file providing entity-level information on inter-company transactions of the MNE; and (3) a country-by-country report providing information on revenues, profits, taxes accrued and paid, capital, headcount, and other indicators.
