The main objective of OECD base erosion and profit shifting (BEPS) Action Item 13 (Transfer Pricing Documentation and Country-by-Country Reporting (CbC Reports)) is to standardize the information provided to tax authorities in order to increase transparency and combat transfer pricing and base erosion risks. One key tool contained in Action 13 to meet this objective is the framework for government-to-government mechanisms to exchange CbC Reports. The framework provides that CbC Reports are automatically exchanged where the relevant jurisdictions execute bilateral competent authority arrangements(CAAs).
Sahar Zomorodi is a member of the Firm’s North America Tax Practice Group in New York, where she works on international tax planning and transactions and transfer pricing matters. Sahar has recently spent a year at the Firm's Amsterdam office, where she provided U.S. tax advice to European based clients. Sahar has over 10 years of experience in transfer pricing in the private sector and the Internal Revenue Service. Prior to joining the Firm, Sahar was an economist and team leader with the IRS's Advance Pricing and Mutual Agreement Program in Washington, DC. Sahar is a frequent speaker at Bloomberg BNA and Baker McKenzie conferences. Sahar also contributes to the Firm’s publications, such as the Global Transfer Pricing Handbook and the Global Legal Guide for Luxury & Fashion Companies. Sahar is an active member of the Firm’s Pro Bono and Diversity Committees.