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

International Bureau of Fiscal Documentation (IBFD), Forthcoming

27 Pages Posted: 12 Feb 2018 Last revised: 16 Feb 2018

See all articles by Michelle Hanlon

Michelle Hanlon

Massachusetts Institute of Technology (MIT) - Sloan School of Management

Date Written: February 5, 2018

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

Suggested Citation

Hanlon, Michelle, Country-by-Country Reporting and the International Allocation of Taxing Rights (February 5, 2018). International Bureau of Fiscal Documentation (IBFD), Forthcoming. Available at SSRN: https://ssrn.com/abstract=3118531

Michelle Hanlon (Contact Author)

Massachusetts Institute of Technology (MIT) - Sloan School of Management ( email )

100 Main Street
E62-668
Cambridge, MA 02142
United States
617-253-9849 (Phone)

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