The Organisation for Economic Co-operation and Development has released its “Country-by-Country Reporting Implementation Package,” which is the key, and most controversial, aspect of a series of recommended changes to fundamentally alter the focus of the transfer pricing documentation from the pricing of specific transactions between specific related parties to the total global value chain of a multinational enterprise. While the US Treasury Department has indicated that it will implement the implementation package through regulations, members of the US Congress have recently questioned Treasury’s authority to do so without new legislation.
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