On 21 December 2015, the U.S. Treasury Department and the IRS issued REG-109822-15, which includes proposed regulations for Country-by-Country (CbC) reporting requirements. The regulations are generally in line with the CbC reporting guidance developed as part of Action 13 of the OECD BEPS Project, with certain exceptions. The proposed regulations do not mention the Master File and Local File concepts, which are part of the Action 13 three-tiered approach to transfer pricing documentation.
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