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First published in BNA Bloomberg Tax Planning International, 30 May 2016.
On April 12, 2016, the European Commission published a proposal on the implementation of an EU-wide automatic exchange regarding country-by-country reporting (CbCR), following the outcomes of the OECD/G-20 Base Erosion and Profit Shifting (BEPS) project.
This proposal for a directive of the European Parliament and the Council, amending Directive 2013/34/EU as regards disclosure of income tax information by certain multinational enterprises (MNEs), is part of a European Commission initiative to improve tax transparency and fight tax avoidance.
Despite its legitimate purpose, the proposal raises some serious concerns. This article describes the Commission’s objectives and subjects the main proposals for the amendment of directive 2013/34/EU to a critical appraisal.
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Clients are advised to review their transfer pricing policy and adjust now, if necessary, to avoid potential corrections in future tax audits. This may involve the co-operation and support of external tax advisors with the relevant practical experience.