In this article, I discuss the OECD country-by-country reporting (CbCR) requirements, the disconnect between CbCR and current tax policy, the potential benefits and costs of CbCR (including misinterpretations of the data), and what all of this might mean for the international allocation of taxing rights. The CbCR requirement is included in the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. It requires certain multinational enterprises (MNEs) to file a report of their income and economic activities aggregated by country. The items required are related-party revenues, unrelated-party revenues, pre-tax profit or loss, cash income tax paid, income taxes accrued, stated capital, accumulated earnings, number of employees and tangible assets.1 The first period for which reporting has been (or will be) completed is for fiscal years beginning on or after 1 January 2016. Currently, 108 countries are in the BEPS Inclusive Framework and all having agreed to implement the four BEPS minimum standards, including Action 13.

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