BEPStoimintalinjat

BEPStoimintalinjat, often referred to as BEPS Action 13, is a set of recommendations developed by the Organisation for Economic Co-operation and Development (OECD) as part of the Base Erosion and Profit Shifting (BEPS) project. The primary objective of Action 13 is to enhance tax certainty and transparency by requiring multinational enterprises (MNEs) to provide tax administrations with information on their global allocation of income, the economic activity in the countries where they operate, and the indicators of the location of their economic activities and the functions performed, assets used and risks undertaken by their affiliates.

The core of BEPS Action 13 is the introduction of a three-tiered approach to transfer pricing documentation. This approach consists of a Master File, a Local File, and a Country-by-Country Report (CbCR). The Master File provides an overview of the MNE's global business operations and its global transfer pricing policies. The Local File contains detailed information about the specific transactions between the MNE's entities in a particular jurisdiction and the application of transfer pricing methods to these transactions. The Country-by-Country Report provides high-level financial and tax data for each jurisdiction in which the MNE operates, including revenue, profit, taxes paid, and other key indicators of economic activity.

The implementation of BEPS Action 13 aims to equip tax administrations with better tools to assess transfer pricing risks and to combat aggressive tax planning by MNEs. It promotes a more standardized and consistent approach to transfer pricing documentation globally, thereby reducing compliance burdens for MNEs and improving tax administrations' ability to detect and address potential profit shifting. Many countries have enacted legislation or regulations to implement these requirements, mandating MNEs to prepare and submit the relevant documentation.