Loyens & Loeff


Loyens & Loeff has launched www.countrybycountryreporting.com, where you can follow the developments on the changes proposed by the OECD/G20 in relation to transfer pricing documentation. On www.countrybycountryreporting.com you can find a Q&A about the three-tiered approach for transfer pricing documentation, as well as a clear overview of countries which have introduced and/or are in the process of introducing (part of) the new transfer pricing documentation requirements ­– including the countries that have signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports.


Background information

On 5 October 2015 the OECD/G20 presented 15 action plans (Action Plans) of the Base Erosion and Profit Shifting project (BEPS Project). The Action Plans create a coordinated international approach to reform the international tax system to ensure that profits of multinational enterprises (MNEs) are taxed where economic activity takes place and value is created.


What can Loyens & Loeff do for you?

The three-tiered approach, consisting of a Master File, a Local File and Country-by-Country Report, needs to be included in the domestic legislation of the participating countries. For MNEs this is expected to result in an increased compliance burden, more questions during audits and increased risk of double taxation. To prepare for this, MNEs regularly approach Loyens & Loeff to develop action plans and build strategies. Together with us, you will be in control and ultimately more efficient, accurate, and prepared for discussions and audits.