Nov 082015
(Second of two parts)
Last week, we began the discussion on the 3-tiered standardized approach to Transfer Pricing (TP) documentation that is prescribed in Base Erosion and Profit Shifting (BEPS) Action Plan 13, which amended certain sections of the Organization of Economic Cooperation and Development Transfer Pricing (TP) Guidelines. This 3-tiered standardized approach requires the preparation of a Master File, a Local File, and Country-by-Country Report (CBCR), following a prescribed template.