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Internationally operating companies face major challenges in the area of international taxation. In 2013, the OECD and G20 countries launched the initiative to combat base erosion and profit shifting (BEPS) to the detriment of international tax revenues. As part of this initiative, the tax administrations of the OECD countries are developing a plan of action with concrete proposals to combat undesirable tax planning.  

The so-called Country-by-Country Reporting (CbCR for short) is part of the action plan and serves the goal of creating more transparency in the fight against international tax planning. The introduction of CbCR for international groups with parent companies in the OECD and G20 countries is no longer reversible. The OECD foresees the introduction of the reporting obligations for the first time for financial years beginning on or after 1 January 2016. 

In view of the impending double taxation risks as well as the challenges posed by a new compliance obligation, affected companies should analyse the effects of the CbCR for their company as early as possible.

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