The Use of Country-by-Country Reporting for Tax Risk Assessment: Challenges and Potential Solutions

This article provides some considerations on the use of the country-by-country reporting for tax risk assessment through an in-depth review of the potential issues associated with the implementation, design and appropriate use of the country-by-country report. After providing a broader conceptual framework that outlines the general benefits of incorporating the report into a tax authority’s risk assessment framework, the article specifically suggests potential areas for improvement in respect of how to address the different issues and examines whether modifications should be made to the standard, especially in light of the forthcoming 2020 review.. Such recommendations are addressed to tax administrations and multinational enterprise groups, since inefficient use will be burdensome for both parties The analysis also takes into consideration the recent public consultation draft issued by the OECD.