Page 330 - International Taxation IRS Training Guides

BEPS Reports (Cont’d)

 Action 11: Measuring and Monitoring BEPS

 Action 12: Mandatory Disclosure Rules

Pricing Documentation and
 Action 13: Transfer

Country-by-Country Reporting

• Minimum standard: Automatic
exchange of country-by-country
reports

 Action 14: Making Dispute Resolution Mechanisms

More Effective

standard: Peer review of certain aspects of mutual
• Minimum
procedures (MAP) regime
agreement

Instrument to
 Action 15: Developing a Multilateral

Modify Bilateral
Tax Treaties

14