Technology Industries of Finland’s comments on the OECD’s public consultation document: Review of Country-by-Country Reporting

Fri, 03/06/2020 - 14:37
The OECD, countries and companies have invested great effort in implementing the current CbCR procedures and no substantial changes should be made at this point, also considering the OECD’s ongoing work on Pillar 1 (change in corporate taxation of consumer facing business) and Pillar 2 (minimum tax) proposals. TIF highlights that CbCR is to be used only for its original purpose: as a high-risk assessment tool. Not a base for taxation.

In Pillar 1, Amount A -model proposed new nexus cannot trigger a CbCR reporting responsibility. TIF supports the 750 MEUR threshold and suggests it is not lowered, so that SMEs will not be burdened with too heavy administrative work. It is also in line with the proposed threshold of Pillar 1 Amount A -model and possibly also Pillar 2 minimum tax -model. Filing formats, processes, timing and frequency should be standardized. This will reduce the administrative burden of companies and tax authorities as well as enhance digitalisation and automation of taxation procedures. TIF is opposed to public CbCR. The tax administrations already receive the necessary data for conducting taxation. Publicly reporting is an unnecessary administrative burden, including high risk for misinterpretations and request to reveal commercially sensitive data. 

Read the whole statement: