BEPS: Are CbC Surrogate a Reporting Trap?
Yes, according to Strategizing International Tax Best Practices (by Keith Brockman).
In a recent blogpost, Mr. Brockman highlighted with respect to BEPS Country-by-country (CbC) reporting:
“A review of CbC legislative actions by different countries reveals that such legislation will be inconsistent and will require the multinational to file separate CbC reports in various countries, irrespective of its choice of appointing a surrogate country that has an extensive tax treaty network with exchange of information provisions.”
See Mr. Brockman full analysis here : http://strategizingtaxrisks.com/2016/01/31/cbc-surrogate-a-reporting-trap/
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