The OECD has published a 42-page Country-by-Country Reporting Implementation Package this week, which consists of model legislation, a multilateral competent authority agreement on the exchange of country-by-country reports, two other competent authority agreements, one based on a double tax convention, the other based on a tax information exchange agreement (TIEA), and a confidentiality and data safeguards questionnaire.
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals