{"id":124,"date":"2018-04-21T00:13:01","date_gmt":"2018-04-21T00:13:01","guid":{"rendered":"http:\/\/qcg.stylereport.com.mx\/?p=124"},"modified":"2025-03-16T14:46:47","modified_gmt":"2025-03-16T20:46:47","slug":"action-13-of-the-beps-plan-country-by-country-reporting-and-transfer-pricing-documentation","status":"publish","type":"post","link":"https:\/\/qcgtransferpricing.com\/en\/blog\/action-13-of-the-beps-plan-country-by-country-reporting-and-transfer-pricing-documentation\/","title":{"rendered":"Action 13 of the BEPS Plan: Country-by-Country Reporting and Transfer Pricing Documentation"},"content":{"rendered":"

Toward an Era of Tax Transparency<\/h3>\n

One of the most visible actions of the BEPS plan is Action 13 (country-by-country reporting and transfer pricing documentation). This action aims to enhance transparency for tax purposes by clarifying how multinational groups are organized and conduct intercompany transactions. Action 13 has come into effect, modifying Chapter V of the Transfer Pricing Guidelines for 2017, and in Mexico, through the incorporation of Article 76-A of the Income Tax Law in 2016.<\/p>\n

The Three-Tiered Documentation Standard Proposed by Action 13<\/h3>\n

Action 13 of the BEPS plan, which amends Chapter V (Documentation) of the OECD Transfer Pricing Guidelines for 2017, establishes a three-tiered standard for compliance with documentary obligations. As a result, multinational groups required to comply must compile their intercompany operations through a Master File<\/strong>, a Country-by-Country Report<\/strong>, and a Local File<\/strong>, which must be prepared annually. The information required in each of these documents is as follows:<\/p>\n

Master File<\/strong><\/h4>\n

The Master File<\/strong> provides a general overview of the multinational group\u2019s economic activity and its transfer pricing policies. The information required in the Master File includes:<\/p>\n

    \n
  1. The organizational structure of the multinational group<\/li>\n
  2. A description of the group\u2019s business lines<\/li>\n
  3. The group\u2019s intangibles<\/li>\n
  4. Financial activities<\/li>\n
  5. Financial and tax positions, specifically consolidated financial statements of the multinational group, as well as information related to advance pricing agreements (APAs) and\/or “tax rulings” granted by any tax authority.<\/li>\n<\/ol>\n

    Action 13 of the BEPS plan allows each country to determine which taxpayers are required to submit the Master File. It is important to note that, due to general requirements on certain topics, the information presented by multinational groups in the Master File may vary in structure, detail, and analysis methods. Therefore, both the multinational group and its subsidiaries must be involved in preparing the Master File to ensure the final documentation accurately reflects its operations. Additionally, the Master File must include information on the adequacy of the group\u2019s transfer pricing policies concerning other BEPS actions, particularly Actions 8-10.<\/p>\n

    Country-by-Country Report (CbC Report)<\/strong><\/h4>\n

    The Country-by-Country Report (CbC Report)<\/strong> provides information on each subsidiary of the group through three forms or tables:<\/p>\n