When your multinational enterprise (MNE) has consolidated annual group revenues of 750m+, you most likely need to file a Country-by-Country (CbC) Report for financial years starting on or after 1 January 2016.
Be prepared; develop an action plan and strategy
The expected impact for you as an MNE is an increased compliance burden, more questions during audits and potentially risks of double taxation. To prepare for this, we advise you to develop an action plan and build a strategy:
- Determine whether CbC Reporting obligation exists
- Preparation of resources
- Collection of data
- Analysis of data
- Identify and respond to strategic opportunities
What we can do for you
With the right approach your MNE will be more efficient, accurate and prepared for discussions and audits. Together with us you can prepare a CbC Report that leads to the desired outcome in an efficient manner. We will assist and advise you:
- on choices to be made regarding input data
- in ‘mapping’ and interpretation of definitions
- in dry run of several countries & analyse outcome
- on restructuring to reduce ‘red flags’.
The so called ‘dry-run’ on latest figures of a limited number of test countries will allow your MNE to identify red flags, inconsistencies and potential vulnerabilities. Subsequently, these can be corrected and the transfer pricing policy can be amended where necessary.
CbC Reporting incorporating countries
Many countries around the world are incorporating the CbC Reporting requirements into their domestic legislation to varying degrees.
This map shows all countries that have introduced and/or are in the process of introducing (part of) the new transfer pricing documentation requirements
NatalieReypensAttorney at Law Partner
Natalie Reypens is a member of the Loyens & Loeff International Tax Services Practice Group and heads the Belgian Transfer Pricing Team. She is a partner in our Brussels office. She focuses on corporate and international tax law.T: +32 2 743 43 37 E: email@example.com