Examples of CbC Report in a sentence
Such CbC Report is intended to be exchanged as soon as possible and no later than 18 months after the last day of the Fiscal Year of the MNE Group to which the CbC Report relates.
A CbC Report is intended to be first exchanged with respect to Fiscal Years of MNE Groups commencing on or after January 1, 2016.
CbC Reports with respect to Fiscal Years of MNE Groups commencing on or after January 1, 2017 are intended to be exchanged as soon as possible and no later than 15 months after the last day of the Fiscal Year of the MNE Group to which the CbC Report relates.
Each Competent Authority acknowledges that information in the CbC Report on its own does not constitute conclusive evidence that transfer prices are or are not appropriate and, consequently, the tax administration should not base transfer pricing adjustments on the CbC Report.
Within 15 days of successfully receiving a file containing the CbC Report in the time and manner described in Section 3, the Competent Authority receiving the file is expected to provide notice of such successful receipt to the Competent Authority providing the file.
The CbC Report data may be used as a basis for making further inquiries into the MNE Group’s transfer pricing arrangements or into other tax matters in the course of a tax audit and, as a result of such further inquiries, making appropriate adjustments to the taxable income of a Constituent Entity.
Where a person considers that an adjustment to the taxable income of a Constituent Entity, as a result of further inquiries based on the data in the CbC Report, results for such person in taxation not in accordance with the provisions of the Convention and presents its case to the Competent Authority specified in the Convention, the Competent Authorities acknowledge their obligation to endeavor to resolve the case under Article 25 of the Convention.
In particular, information exchanged by means of the CbC Report should be used by the tax administration for assessing high-level transfer pricing risks, base erosion and profit shifting related risks, and, where appropriate, for economic and statistical analysis.
For the purposes of the exchange of information in Section 2, the amounts contained in each CbC Report are expected to be stated in a single currency, which is expected to be specified in the CbC Report.