Editorial: The Ed Sheeran of transfer pricing
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 landscape.
In Japan, Timothy O'Brien, Takuma McNie and Luke Tanner of Deloitte Tohmatsu Tax explore the ins and outs of the new documentation requirements.
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.