Public country-by-country reporting for large multinational enterprises

In connection with the upcoming evaluation of the international standard for automatic exchange of country-by-country reports for tax purposes, Norway is considering the possibility of introducing a global commitment for public country-by-country reporting for large multinational enterprises.

Completion Status:
⚠ Unqualified*

*commitment is not specific or/and not measurable

Commitment filtering:

Specific:yes

This commitment is considered specific because it refers to a concrete anti-corruption mechanism (country-by-country reports for tax purposes) and initiative (the evaluation of the international standard for this mechanism). The initiative is framed under the Base Erosion and Profit Shifting (BEPS) Action 13, requiring all large multinational enterprises to prepare country-by-country reports with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which they operate.[1] With the overall goal of preventing tax avoidance by corporations, the BEPS Action 13 report (Transfer Pricing Documentation and Country-by-Country Reporting) provides a template for multinational enterprises to report annually and for each tax jurisdiction in which they do business. Under the BEPS Action 13, OECD members planned a review of the country-by-country reporting minimum standard in 2020. Norway signed the multilateral competent authority agreement on the exchange of country-by-country reports in 2016. It was part of the 2017-2018 and the 2018-2019 peer reviews, which were supplemented with the review of the third phase published in 2020.[2]

[1] OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS), Action 13, Country-by-Country Reporting, https://www.oecd.org/tax/beps/beps-actions/action13/

[2] Organisation for Economic Co-operation and Development (OECD), OECD/G20 Base Erosion and Profit Shifting Project, https://www.oecd-ilibrary.org/docserver/fa6d31d7-en.pdf?expires=1640026915&id=id&accname=guest&checksum=E28D299E407FFB43272716BAE67802D7

Measurable: ❌ no

The commitment is not considered measurable because the language used to formulate it is non-committal (“Norway in considering”). Feedback from Norway’s government highlights that this is still a long-term goal, but that there is currently not enough support globally to move it forward. Besides adopting committal language, such a commitment could be made more measurable in future by narrowing it through promising concrete actions on how the Norwegian government wants to get other countries on board.



Last updated: 30 August 2022
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