Country-by-Country Tax Reporting: A Critical Analysis of Enhanced Regulatory Requirements for Multinational Corporations

Abstract

As part of the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting project, country-by-country reporting (CbCR) has been promoted as a mechanism to enhance transparency with respect to the operations and tax planning activities of large multinational corporations. CbCR involves the disclosure by a company, either publicly or in confidence to governments, of tax figures and, potentially, other financial data on a country-by-country basis for all jurisdictions in which it operates. In this article we adopt a cross-country comparative case study analysis, involving two jurisdictions which have implemented CbCR. This article provides a critical analysis of a series of semi-structured interviews conducted in Australia and New Zealand with key tax professionals, along with revenue officials, with the aim of ascertaining the views of the profession and their multinational corporate clients on the new CbCR requirements. The findings not only reinforced our prior expectations based on documentary analysis that the approaches of the two jurisdictions would differ but revealed significant differences in the level of involvement of tax practitioners in preparing for CbCR for corporations, and between large- and mid-tier firms.