In recent years there has been an international emphasis on improved standards and systems of tax transparency and an effort to combat base erosion and profit shifting (BEPS) due to governments’ need for revenue and the efforts of multinational enterprises (MNE) to minimise taxation.

Base erosion describes the act of reducing the level of taxable profits in a jurisdiction, while profit shifting involves moving the profit on an activity from one tax jurisdiction to another jurisdiction, usually to benefit from a lower tax rate.

The Organisation for Economic Co-operation and Development (OECD) aims to tackle BEPS by reforming the way in which tax systems work internationally. One tool developed by the OECD to tackle BEPS is the implementation of country-by-country (CbC) reporting.

This article discusses the history of the OECD’s CbC regime and provides an overview of CbC reporting and the implications of the Multilateral Competent Authority Agreement on the Exchange of Country-By-Country Reports signed by Bermuda in April 2016 (MCAA).

In 2013, the OECD and G20 countries adopted the Action Plan on Base Erosion And Profit Shifting (BEPS Action Plan). The BEPS Action Plan set out 15 key actions to reform the way in which tax systems work internationally and address a variety of issues surrounding tax transparency, accountability, information exchange and BEPS.

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