The New World of Global Tax Planning: a Checklist for Success -

As all multinationals (MNEs) are discovering, domestic implementation of the recommendations set out in the base erosion and profit shifting (BEPS) final reports from 2015 has the potential to significantly impact their effective tax rate planning.

The immediate issue flows from the country-by-country (CbC) transfer pricing (TP) documentation process. Many countries (including China, Japan, Italy and the United Kingdom) have implemented domestic legislation effective for 2016, and the United States has finalized regulations that will come into effect in 2017. A multilateral instrument relating to CbC is well underway, and is expected to impose the CbC requirements on all 3,000+ existing treaties.