Enhanced Tax Reporting Requirements under the BEPS Project: Preparing the Profession
As part of the OECDís Base Erosion and Profit Shifting (BEPS) project, country by country reporting (CbCR) has been promoted as a mechanism to enhance transparency with respect to the operations and tax planning activities of large multinational enterprises. CbCR involves the disclosure by a company, either publically or in confidence to governments, of tax figures and, potentially, other financial data on a country-by-country basis for all jurisdictions in which it operates. In this paper we adopt a cross-country comparative case study analysis, involving two jurisdictions, Australia and New Zealand, which have implemented CbCR. This paper reports on a series of semi-structured interviews conducted with key tax professionals in large chartered accountancy (CA) firms, along with revenue officials, with the aim of ascertaining the readiness of the profession and their MNE clients for CbCR. The interviews not only reinforced our prior expectations based on documentary analysis that the two jurisdictions approaches would differ, but revealed significant differences in the level of involvement of tax practitioners in preparing for CbCR, and between the Big 4 and mid-tier CA firms. At this stage our analysis should be interpreted with caution as CbCR is yet to be fully implemented across all jurisdictions that have indicated their commitment to it, and the implications from revenue authoritiesí analysis of the reports have yet to be experienced.