Country‐by‐Country Reporting: The New OECD Guidelines and IRS Final Regulations

Because transfer pricing strategies can artificially shift the recognition of business profits to relatively low‐tax or no‐tax jurisdictions, global tax authorities find it challenging to fairly and consistently measure the economic value created by multinational enterprises in a given country. Action 13 of the OECD/G20 Base Erosion and Profit Shifting Project provides an inclusive framework to address these challenges including a template for annual country‐by‐country reporting of revenues, profits, and taxes paid. In the United States, final regulations have established the reporting requirements for U.S. multinational enterprise groups for taxable years beginning on or after June 30, 2016, when annual revenues exceed $850 million. © 2017 Wiley Periodicals, Inc.