Country-by-Country Reporting and the International Allocation of Taxing Rights

Abstract

In this paper, I discuss the OECD/BEPS country-by-country reporting requirements and the disconnect between country-by-country reporting data and current tax policy of the arm’s length principle of transfer pricing. I also discuss potential benefits of country-by-country data as well as potential costs, such as increased compliance costs, future controversy costs, and possible misinterpretations of the data. I end by considering what implications country-by-country reporting might have for the international allocation of taxing rights.

Keywords: Tax, Tax Policy, Tax Reporting, International Tax, Country-by-Country