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

In this article, the author examines the OECD/BEPS country-by-country reporting (CbCR) requirements and the disconnect between CbCR data and the arm’s length principle, discusses the potential benefits and costs of country-by-country data, and concludes by considering the possible implications of CbCR for the international allocation of taxing rights.