Action 13: Transfer pricing documentation and country-by-country reporting

December 15 2015

The effective implementation of the arm’s-length principle is closely linked to the availability of information. In transfer pricing, the asymmetry of information between taxpayers and tax administrations can be acute, potentially opening opportunities for BEPS. For this reason, the BEPS Action Plan stressed the need to enhance transparency in general, and for transfer pricing purposes in particular. Andrew Hickman, Samia Abdelghani and Paul Hondius explain these enhancements in the context of Action 13.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

The pillar two side-by-side agreement: key questions answered

From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal

Russell Gammon, March 17 2026

Direct Tax

Tax campaigners clash on pillar two as side-by-side deal costs emerge

Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’

Sam Sholli, March 16 2026

Direct Tax

A taxing week: WTS enters fierce battle for global tax advisory supremacy

The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player

Tom Baker, March 13 2026

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

This week in tax: HMRC defers tax agent registration for financial services businesses

The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions

Sam Sholli, March 13 2026

Transfer Pricing

HMRC almost doubles revenue from TP cases in one year

Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed

Sam Sholli, March 12 2026

Direct Tax

Dan Neidle defeats £8m libel claim brought by ‘tax avoidance promoter’

The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs

Sam Sholli, March 11 2026

Indirect Tax

Opinion: Tariff turbulence is a wake-up call for IP attorneys

IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing

Sanjana Mishra, March 11 2026

Transfer Pricing

Is Coca-Cola’s ‘Black Swan’ event in sight?

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency

Alex Martin, March 10 2026

Direct Tax

Gender equality has improved ‘significantly’: 79% of female tax advisers

However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed

Tom Baker, March 09 2026

Direct Tax

Former EY tax leader spearheads WTS UK launch

Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four

Tom Baker, March 09 2026