Global Tax Policy in Transition: The Rising Importance of CbCR

As the global economy becomes increasingly interconnected, transparency in multinational tax practices has emerged as a hot topic for tax administrations worldwide. Tax transparency in the context of multinational enterprises (“MNEs”) refers to the regulatory and statutory requirements that MNEs openly disclose relevant tax-related information to stakeholders or even the public at large. Although the concept of tax transparency has been around for some time, it took off in earnest with the release of the OECD’s mandatory Country-by-Country Reporting (“CbCR”) rules under BEPS Action 13 in 2015. The recent OECD BEPS 2.0 proposals (namely “Pillar Two”) has propelled CbCR from ...