OECD Releases Draft of Radical Country-by-Country Reporting Template

The OECD has just published its draft of “A Model Template of Country-by-Country Reporting” that would require companies for the first time to provide tax administrations with exhaustive details of how they allocate their income, taxes, and business activities on a country-by-country basis.

The draft template—which is subject to comments and a public consultation—requires a company for each country in which it operates to list their “constituent entities,” effective place of management, and important business activities.

In addition, the draft template would also require a company to report on a country-by-country basis its revenues, earnings before income tax, income tax paid on a cash basis to the country of organization and to all other countries, total withholding tax paid, stated capital and accumulated earnings, number of employees, total employee expense, tangible assets other than cash and cash equivalents, royalties paid to constituent entities, royalties received from constituent entities, interest paid to constituent entities, interest received from constituent entities, service fees paid to constituent entities, and service fees received from constituent entities.

The OECD’s draft template may be found at http://www.oecd.org/ctp/transfer-pricing/discussion-draft-transfer-pricing-documentation.pdf

Kevin A. Bell, Staff Writer, Transfer Pricing Report