CbCR as Part of the Three-Tiered Approach to Transfer Pricing
- January 12, 2018
- Posted by: Administrator
- Category: Alert, Tax News
As stipulated within the OECD/G-20 BEPS Report Action 13, the CbCR requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which a Multinational Enterprise (“MNE”) group operates.
The requirement for the CbCR was first introduced in Indonesia through PMK-213 on 30 December 2016 and further clarified through PER-29 on 29 December 2017.