As the deadline on December 31, legal entities referred to in Article 32-H sections I, II, III, and IV of the Federal Tax Code, which engage in related party transactions, as long as these are within the assumptions provided in subparagraphs a) and b) of the third paragraph of section III of article 76-A of the Income Tax Law, must file the Country-by-Country Report.
Country-by-Country Report
This Report is a tool designed to allow tax administrations to perform high-level Transfer Pricing risk analysis. In addition, it also assesses other risks related to Base Erosion and Profit Shifting (BEPS).
In this regard, multinational companies must annually provide, for each jurisdiction in which they operate, aggregated information related to the global allocation of income and taxes paid by the multinational company, along with certain indicators of the location of business activity within the multinational company group, as well as information on which entities do business in a given jurisdiction and the business activities in which each entity participates.
