The Action 13 of the Base Erosion and Profit Shifting (BEPS) report which was published on 5 October 2015 contains revised standards for transfer pricing documentation and a template for country-by-country reporting of income, taxes paid and certain measures of economic activity, both of which will be included in the OECD transfer pricing guidelines.

In brief, it is aimed to develop “rules regarding transfer pricing documentation and to enhance transparency for tax administration, taking into consideration the compliance
costs for business.”

Multinational Enterprises (MNEs) will be required to provide all relevant governments with the information on their global allocation of the income, economic activities and taxes paid among countries according to a common template.