Transfer Pricing and CbCR online tool from Mazars: Rapid, online identification and comparison of regulations in almost 50 countries

The OECD’s Base Erosion and Profits Shifting (BEPS) Action Plan has initiated profound changes to how tax authorities assess transfer pricing. Gradually, governments and entities around the world are introducing a number of recommendations included in the BEPS Action Plan, into domestic legislation. Although efforts have been made to coordinate the implementation of these recommendations, the uptake has not been universal, and as such there are timing differences  as to when the recommendations will be introduced, if at all. The absence of such coordination presents major challenges to multinational enterprises (MNEs) in terms of compliance with both current and future tax liabilities, although efforts have been made to improve the situation.

In recognition of this, Mazars has developed a tool that allows users to identify and compare local country transfer pricing requirements and country-by-country reporting liabilities across jurisdictions.

The Transfer Pricing and CbCR platforms provide an important tool for the rapid, online identification and comparison of regulations in 49 countries. The continuously expanding databases provide stakeholders with up-to-date information about transfer pricing in 47 countries and CbCR requirements in 49 countries, ranging from Argentina to Thailand, including Malta and most European states.

These new innovative platforms provide an important solution for the use of tax professionals, especially since transfer pricing is an essential part of the OECD’s BEPS plan to tackle tax avoidance, and improve transparency and the international exchange of information.

Users can find practical information on different implementation statuses and summaries of CbC reporting, transfer pricing reporting details, as well as country-specific information, such as deadlines and penalties. This is a concrete answer to the OECD’s desire to increase transparency on Transfer Pricing documentations.

How does it work?

Currently the Transfer Pricing Rules 2017 tool contains transfer pricing rules from 47 different countries. The Country by Country Reporting 2017 contains country by country reports from 49 countries. Both platforms enable you to see the rules per country, to compare the situation in various countries, and to compare different criteria. Please note that although you can select up to six  countries, you can compare all the different criteria.

To access the online tool, visit:


Paul Giglio
Tax partner, Mazars