Country-by-Country reporting was implemented as part of Action 13 of the OECD/G20 BEPS Project to support jurisdictions in fighting base erosion and profit shifting (BEPS). While the main purpose of Country-by-Country Reports (CbCRs) is supporting tax administrations in high-level detection and assessment of transfer pricing and other BEPS-related risks, data collected from CbCRs can also play a relevant role in supporting the economic and statistical analyses of multinational enterprises (MNEs). The contribution of this paper is to demonstrate, for the first time in the currently developed literature, how the use of the BEPS Country by Country Report can allow getting to an overall representation and exhaustive analysis of a MNE, the identification of the economic flows between the units of a multinational group and, thus, obtaining more information for a correct estimate of the GDP (Gross Domestic Product) and the GNI (Gross National Income).

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The Use of the BEPS Country by Country Report for the Purpose of Representing the Structure of MNEs and Recording the Economic Flows Between Units for Estimating GDP and GNI

  • Gianna Greca

摘要

Country-by-Country reporting was implemented as part of Action 13 of the OECD/G20 BEPS Project to support jurisdictions in fighting base erosion and profit shifting (BEPS). While the main purpose of Country-by-Country Reports (CbCRs) is supporting tax administrations in high-level detection and assessment of transfer pricing and other BEPS-related risks, data collected from CbCRs can also play a relevant role in supporting the economic and statistical analyses of multinational enterprises (MNEs). The contribution of this paper is to demonstrate, for the first time in the currently developed literature, how the use of the BEPS Country by Country Report can allow getting to an overall representation and exhaustive analysis of a MNE, the identification of the economic flows between the units of a multinational group and, thus, obtaining more information for a correct estimate of the GDP (Gross Domestic Product) and the GNI (Gross National Income).