Duff & Phelps' Global Transfer Pricing Specialists Published in Bloomberg BNA's Transfer Pricing Forum: October 2017 Issue

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Patrick McColgan, a managing director, Emily Sanborn, a director, Andrew Cousins, a director, and Stean Hainsworth, a director in Duff & Phelps' global transfer pricing practice, provide U.S., UK and Australia perspectives regarding turning "corporate tax transparency" into a "big brother" regime. In the October 2017 issue, topics covered include commentary on two parts:

  1. The Organization for Economic Co-operation and Development (OECD)'s master file and local file documentation requirements, unlike the CbC report, are requirements set by each country, even though the OECD has published guidance on what it believes should be included in them. These two reports are not BEPS minimum standards, and therefore are open to modifications or additions by countries to suit their perceived tax needs. At the same time, some governments and many NGOs are pushing for public disclosure of corporate tax information. The combination of these two factors could lead to significant leakage of corporations' tax information.
  2. In addition to the master file and local file, countries are now exchanging information about rulings, and some are requiring reporting of aggressive tax structures or transactions.
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