We have made a submission to the consultation by the OECD on behalf of the Inclusive Framework for BEPS, for its review of the system of Country by Country Reporting (CbCR).

While we welcome the establishment of the system, we note that very few developing countries have yet received any reports, and are concerned that instead of being an effective transparency measure it is being used to discipline how countries apply their own tax rules. It’s now time to require publication of CbCRs, which do not contain commercially confidential information, and improvements to the template should not change this. Key improvements include revision of the definition of a Constituent Entity to include all activities that may create taxable presence, and clarification that tax paid should refer to the country that receives the tax.

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