Chapter 2 considers the scope of CbC reporting, including the definition of an MNE group, and the level and operation of the consolidated group revenue threshold. The OECD is currently developing a CbCR Tax Risk Evaluation & Assessment Tool (TREAT), which will support tax administrations in reading and interpreting CbCR reports. This may be helpful for MENA tax authorities and also for MNEs if TREAT is applied to assess risk and eliminate lower risk MNEs from transfer pricing audit scrutiny. Key Concerns—Divergences from the OECD ApproachThe MENA tax authorities are adopting the master file and local file template and approach and this is helpful for MNEs to have a consistent standard. However, the consultation poses the question as to whether separate CbCRs should be prepared by groups that are under common control and which in aggregate have consolidated group revenue above the CbC reporting threshold.

Source: The North Africa Journal February 26, 2020 08:03 UTC