Country-by-country tax reporting
Healthcare and life sciences companies operating across borders are under direct pressure from country-by-country reporting obligations administered by the Organisation for Economic Co-operation and Development's Inclusive Framework, the U.S. Internal Revenue Service, and the European Commission's Directorate-General for Taxation and Customs Union. The OECD's Pillar Two global minimum tax rules, now being transposed into domestic law across APAC and EU member states at uneven pace, are forcing tax and compliance teams to reconcile transfer pricing structures built around IP-heavy pharma and MedTech models with new local filing formats. For multinationals in this sector, the mismatch between where R&D costs sit and where revenue is recognized is the live fault line.
Watch
- OECD Pillar Two GloBE Rules: qualified domestic minimum top-up tax elections by jurisdiction
- IRS Form 8975 filing accuracy for pharma entities with cost-sharing arrangements
- EU Public CbCR Directive: member-state transposition deadlines running through fiscal year 2025
- Transfer pricing scrutiny on intercompany IP licensing between U.S. parent and offshore manufacturing entities
Recent material activity in Healthcare & Life Sciences
Active monitoring in place across Healthcare & Life Sciences. Material developments related to country-by-country tax reporting will appear here as they are published.