The US is front and center in implementing the final report Action 13 of the international project to combat base erosion and profit shifting (BEPS). In this article published in Bloomberg BNA, the authors discuss the importance of country-by-country reporting and the essential roles each member country’s tax administration and business taxpayers have in implementing the BEPS country-by country report. They explain how to make transfer pricing BEPS proof.
OECD issues guidance on transfer pricing implications of COVID-19
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...