The deadline for ‘Significant Global Entities’ (SGEs) to lodge Country-by-Country (CbC) reporting statements has been extended until 15 February 2018. The CbC reporting statements comprise the Master file, Local file, and CbC report. This is great news for December balancers that have prepared or are in the process of completing the Local Files but require more time for their headquarters to finalise the CbC reporting statements.
Our firm has the experience and relevant tools for assisting SGEs (Head offices and Subsidiaries) to prepare, review and lodge Master File, Local File and CbC reporting. If you need assistance contact our team members.
CbC reporting applies to particular types of SGE. An entity is an SGE for an income year if it is:
Australia implemented a Local File that is substantially different to the Local File proposed by the OECD in Chapter V of the OECD Guidelines. The Australian Local File contains more information that the OECD Local File and is intended to be an additional ‘form’ with disclosures similar to the Tax Return disclosures in the International Dealings Schedule. For this reason, taxpayers need local assistance with completing and submitting the Local File in Australia.
Australia’s Local File comprises a short-form Local File, Local File part A and Local File part B. The three Sections need to be completed by taxpayers unless they are eligible to complete the short form Local File Only.
A reporting entity is required to provide a short-form local file only to the ATO if it meets at least one of the following criteria:
The short-form exceptions list includes transactions as follows:
The CbC statements including Master File and Local File need to be in XML schema before electronic lodgement via one of these channels:
Administrative penalties for statements and failure to lodge on time penalties have increased as of 1 July 2017 for SGEs. Failure to lodge tax documents including CbC statements on time will attract maximum potential penalties ranging from A$ 105,000 to A$ 525,000 (dependant on timing).
Contact Transfer Pricing Solutions
+61 (3) 59117001
Thec Covid-19 pandemic has triggered the most severe recession and is causing enormous damage to the world economy. The economic downturn will impact a group’s transfer prices, analysis and documentation, more so with the BEPS Action Plans in place and the high level of transfer pricing scrutiny across the globe.
JobKeeper forms part of taxable income in the tax return. Makes sense, it is a subsidy against wages, so I am sure there are no surprises there, but how do you assess the arm’s length financial outcomes of the entity for transfer pricing purposes?
The ATO expect that Australian entities will retain the benefit of the JobKeeper payment they receive. So how do you treat the JobKeeper payments for transfer pricing purposes?