OECD releases updated guidance on Country by Country Reporting
The OECD released additional guidance on implementation of country-by-country reporting, as set out in the Action 13 Report "Transfer Pricing Documentation".
Transfer pricing relates to all aspects of intra-group pricing arrangements between related business entities. The transfer pricing policies of MNC’s have recently attracted a high level of international attention, due in part to the rapid rise of multinational trade, the opening of several developing economies and the increased impact of transfer pricing on corporate income taxation.
In Ireland, transfer pricing rules apply to a wide range of related party transactions, including those between two Irish companies. In principle, the rules cover almost everything from sales or purchases of goods and services to intellectual property and financing transactions.
With over 3,000 transfer pricing professionals, across 80 countries, we are the world’s leading adviser* for transfer pricing.
Our transfer pricing team in Ireland has extensive experience in leading and coordinating international projects to develop and implement intra-group transfer pricing models, to assist with dispute resolution and to prepare transfer pricing documentation across all industries, including financial services where we have dedicated transfer pricing specialists in the following sectors: insurance, asset management, banking & capital markets and aircraft leasing.
We can help with the following:
*The Global Tax Monitor recognises PwC as the leading adviser globally and in Ireland for transfer pricing, by reputation, with a very strong lead over the competition. These results are based on the year-ending Q4 2013 figures, with a sample size of 4,060 primary buyers of tax services globally.