Country-by-Country Reporting on Fast Track at OECD

Country-by-country reporting is the number-one concern for multinational corporations today. The initiative, part of the OECD’s project on base erosion and profit shifting (BEPS), is on a fast track, with the organization set to issue draft guidance in February targeted for completion in May.

Key questions are about the initiative, designed to allow tax authorities around the world to see a company's total income and tax payments, are:

How will taxpayers be required to report this information?

Will tax authorities use information obtained from the country-by-country reports to challenge positions in connection with other parts of the BEPS project, such as  the treatment of intangibles and risk?

What safeguards are planned for keeping the information confidential?

Panelists at the Global Transfer Pricing Conference in Paris March 31-April 1 who will address this topic include Mary Bennett of Baker & McKenzie, formerly head of tax treaty, transfer pricing, and financial products for the OECD’s Center for Tax Policy and Administration; Giammarco Cottani of the Italy Revenue Agency; William Morris, director of global tax policy for GE, London; and Jeffrey Owens, former OECD tax chief, now a professor at the Vienna University of Economics and Business.

In addition to country-by-country reporting, the panel will address more broadly the push for transparency in the transfer pricing area, which has led to parliamentary hearings, tax raids, and greatly increased information exchange among tax administrations.

The conference agenda is available at

 Molly Moses, Managing Editor, Transfer Pricing Report