31 countries, including Italy, signed an agreement on January 27th to automatically share "country-by-country" tax information in an effort to increase transparency among multinational enterprises. The agreement will enable tax administrations to better understand how multinational companies are structured globally and ensure their profits are reported where economic activity occurs. It will provide a comprehensive picture of key financial indicators for multinational groups on a country level, helping to ensure they pay appropriate taxes. The first exchanges of information under this new framework will start in 2017-2018 related to company finances from 2016.
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A boost to transparency in international tax matters
1. A boost to transparency in international tax matters
31 countries sign tax co-operation agreement to enable automatic sharing of country by country
information.
As part of continuing efforts to boost transparency by multinational enterprises (MNEs), 31
countries (include Italy), signed, last 27th of January, the Multilateral Competent Authority
Agreement (MCAA) for the automatic exchange of Country-by-Country reports. The signing
ceremony marks an important milestone towards implementation of the OECD/G20 BEPS Project
and a significant increase in cross-border cooperation on tax matters.
The MCAA will enable consistent and swift implementation of new transfer pricing reporting
standards developed under Action 13 of the BEPS Action Plan.
It will ensure that tax administrations obtain a complete understanding of the way MNEs structure
their operations, while also ensuring that the confidentiality of such information is safeguarded.
“Country-by-Country Reporting will have an immediate impact in boosting international co-
operation on tax issues, by enhancing the transparency of multinational enterprises’ operations,”
said OECD Secretary-General Angel Gurría. “Under this multilateral agreement, information will be
exchanged between tax administrations, giving them a single, global picture on the key indicators
of multinational businesses. This is a much-needed tool towards the goal of ensuring that
companies pay their fair share of tax, and would not have been possible without the BEPS
Project.”
The OECD/G20 BEPS Project set out 15 key actions to reform the international tax framework and
ensure that profits are reported where economic activities are carried out and value created. BEPS
is of major significance for developing countries due to their heavy reliance on corporate income
tax, particularly from MNEs.
G20 Leaders endorsed a wide-ranging BEPS package in November 2015 that marks an historic
opportunity for improving the effectiveness of the international tax system. The package was the
result of more than two years of discussion involving all OECD and G20 countries, as well as more
than a dozen developing countries. Following endorsement of the BEPS measures, the focus has
shifted to designing and putting in place an inclusive framework for monitoring BEPS and
supporting implementation of the measures, with all interested countries and jurisdictions invited
to participate on an equal footing.
With Country-by-Country reporting tax administrations where a company operates will get
aggregate information annually, starting with 2016 accounts, relating to the global allocation of
income and taxes paid, together with other indicators of the location of economic activity within
the MNE group. It will also cover information about which entities do business in a particular
jurisdiction and the business activities each entity engages in. The information will be collected by
the country of residence of the MNE group, and will then be exchanged through exchange of
information supported by such agreements as signed today. First exchanges will start in 2017-2018
2. on 2016 information. In case information fails to be exchanged, the Action 13 report on transfer
pricing documentation provides for alternative filing so that the playing field is levelled.
Countries involved in co-operation agreement: Australia, Austria, Belgium, Chile, Costa Rica, Czech
Republic, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Japan, Liechtenstein,
Luxembourg, Malaysia, Mexico, Netherlands, Nigeria, Norway, Poland, Portugal, Slovak Republic,
Slovenia, South Africa, Spain, Sweden, Switzerland and United Kingdom.
By www.oecd.org