A US multinational subject to Country‑by‑Country Reporting (CbCR) requirements needed to assess its eligibility for the Transitional CbCR Safe Harbour across multiple jurisdictions.
With the introduction of the Transitional CbCR Safe Harbour, taxpayers face questions regarding whether their existing Form 8975 CbCR was prepared in a manner consistent with the requirements for safe harbour eligibility. Given evolving OECD guidance,
CRA’s Transfer Pricing Practice assisted the multinational with an ongoing review of their Form 8975 CbCR filings for Transitional CbCR Safe Harbour eligibility purposes by analyzing the disclosures for alignment with the specific requirements, consistency, and completeness.
CRA’s work helped the MNE to assess eligibility, identify potential issues early, and mitigate risks of disqualification from the Transitional CbCR Safe Harbour.
