It used to be when one talked about country-by-country
reporting (CbCR) and tax transparency, people would look at you
like you were some kind of beret-wearing, fist-raising,
Trotskyist from Tooting shouting "power to the people!"
Returning to the world of tax and transfer pricing after
nearly three years editing a current affairs magazine, I can
see how much things have changed. With the OECD's BEPS project
in full swing, CbCR is about as mainstream as Ed Sheeran. And
just as no fewer than 16 of his songs find themselves
dominating the UK Top 20, it is hardly surprising that this
year's Transfer Pricing guide is dominated by the rollout of
BEPS Actions worldwide.
As Roberto Carlos Rivas and María Carolina Camargo
and of PwC explain, Chile is on the front lines of CbCR as it
is among the first countries to require multinationals to file
a country-by-country report.
The increased transparency brought by such BEPS measures
will inevitably lead to more tax disputes, argue Joe Duffy and
Tomás Bailey of Matheson as they survey the Irish
In Japan, Timothy O'Brien, Takuma McNie and Luke Tanner of
Deloitte Tohmatsu Tax explore the ins and outs of the new
In Sweden, we have Johan Rick of KPMG looking at how OECD
materials can be used to interpret local law.
Meanwhile, David Forst and Larissa Neumann of Fenwick &
West look at all the latest transfer pricing developments to
come out of the US, while Shiv Mahalingham of Duff & Phelps
rounds up UK changes.
I hope you find this guide useful.