An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective

 

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dc.contributor.advisor Hattingh, Johann en_ZA
dc.contributor.advisor Roeleveld, Jennifer en_ZA
dc.contributor.author Van Wyk, Lindie en_ZA
dc.date.accessioned 2016-09-14T12:50:49Z
dc.date.available 2016-09-14T12:50:49Z
dc.date.issued 2016 en_ZA
dc.identifier.citation Van Wyk, L. 2016. An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective. University of Cape Town. en_ZA
dc.identifier.uri http://hdl.handle.net/11427/21752
dc.description.abstract In February 2013, the OECD published a report on its findings concerning base erosion and profit shifting ("BEPS").1 That report, in particular Action Plan 13, dealt with the re-examination of transfer pricing documentation wherein the shifting of profits to lower tax rate jurisdictions is addressed. The OECD proposed a Country-by-Country ("CbC") methodology whereby certain information is required to be disclosed within a Country-by-Country Reporting Template ("the CbC Template"). The main purpose of the CbC Template is to assist tax administrations to identify risks related to base erosion and profit shifting; also, and where applicable, data collected via the CbC Template can be used for economic and statistical analysis. The OECD is of the view that the CbC Template in assisting tax administrators to determine transfer pricing risk, will serve as a high-level risk assessment indicator for transfer pricing. Accordingly, the main aim of the CbC Template is to be a tool for tax administrators to identify and consequently ensure that the revenue of a country is not eroded unfairly. The objective of this paper is to review the CbC Template from a South African perspective and to determine the consequences for taxpayers arising from the information required to be disclosed. It follows that this paper will focus, in particular, on the challenges and consequences that exist within a South African context for a South African taxpayer conducting business in different tax jurisdictions. The paper will further analyse the CbC Template requirements in light of the legislative requirements for Transfer Pricing Documentation in South Africa. en_ZA
dc.language.iso eng en_ZA
dc.subject.other Taxation en_ZA
dc.title An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective en_ZA
dc.type Master Thesis
uct.type.publication Research en_ZA
uct.type.resource Thesis en_ZA
dc.publisher.institution University of Cape Town
dc.publisher.faculty Faculty of Commerce en_ZA
dc.publisher.department Department of Finance and Tax en_ZA
dc.type.qualificationlevel Masters
dc.type.qualificationname MCom en_ZA
uct.type.filetype Text
uct.type.filetype Image
dc.identifier.apacitation Van Wyk, L. (2016). <i>An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective</i>. (Thesis). University of Cape Town ,Faculty of Commerce ,Department of Finance and Tax. Retrieved from http://hdl.handle.net/11427/21752 en_ZA
dc.identifier.chicagocitation Van Wyk, Lindie. <i>"An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective."</i> Thesis., University of Cape Town ,Faculty of Commerce ,Department of Finance and Tax, 2016. http://hdl.handle.net/11427/21752 en_ZA
dc.identifier.vancouvercitation Van Wyk L. An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective. [Thesis]. University of Cape Town ,Faculty of Commerce ,Department of Finance and Tax, 2016 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/21752 en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Van Wyk, Lindie AB - In February 2013, the OECD published a report on its findings concerning base erosion and profit shifting ("BEPS").1 That report, in particular Action Plan 13, dealt with the re-examination of transfer pricing documentation wherein the shifting of profits to lower tax rate jurisdictions is addressed. The OECD proposed a Country-by-Country ("CbC") methodology whereby certain information is required to be disclosed within a Country-by-Country Reporting Template ("the CbC Template"). The main purpose of the CbC Template is to assist tax administrations to identify risks related to base erosion and profit shifting; also, and where applicable, data collected via the CbC Template can be used for economic and statistical analysis. The OECD is of the view that the CbC Template in assisting tax administrators to determine transfer pricing risk, will serve as a high-level risk assessment indicator for transfer pricing. Accordingly, the main aim of the CbC Template is to be a tool for tax administrators to identify and consequently ensure that the revenue of a country is not eroded unfairly. The objective of this paper is to review the CbC Template from a South African perspective and to determine the consequences for taxpayers arising from the information required to be disclosed. It follows that this paper will focus, in particular, on the challenges and consequences that exist within a South African context for a South African taxpayer conducting business in different tax jurisdictions. The paper will further analyse the CbC Template requirements in light of the legislative requirements for Transfer Pricing Documentation in South Africa. DA - 2016 DB - OpenUCT DP - University of Cape Town LK - https://open.uct.ac.za PB - University of Cape Town PY - 2016 T1 - An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective TI - An evaluation of the Country-by-Country Reporting (CbC Template) for transfer pricing documentation purposes from a South African perspective UR - http://hdl.handle.net/11427/21752 ER - en_ZA


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