For the first time, taxing authorities throughout the world will be able to ascertain how multinational companies allocate their income and tax payments to specific countries. The template will also serve as an essential tool for taxing authorities to identify and select companies to be audited. The potential for increased transfer pricing audit activity is an expected outcome of the CbC filings when they begin for tax years effective January 1, 2016 in some countries. Countries are still continuing to adopt for 2016.
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