The Tax Programme of the OECD Korea Policy Centre, in collaboration with the OECD and the China Tax Centre, hosted the OECD Global Relations Programme from November 19–21, 2024. The workshop, held online via Zoom, focused on "Country-by-Country Reporting." It was attended by 528 tax officials from 90 countries. Instructors from the OECD included Mark Johnson, Mayra Lucas, Nicole Casey, Lloyd Garrochinho, Mark Scott, and Matthew Coakley.

On Day 1, Mark Johnson and Mayra Lucas provided an overview of country-by-country reporting and transfer pricing documentation. Mark Johnson explained that BEPS Action 13, one of the minimum standards, requires multinational enterprises to report tax information transparently. He emphasized that this prevents tax avoidance and increases the efficiency of tax administration. He also noted that countries such as Malaysia, the UK, and Indonesia have fully implemented BEPS Action 13. Johnson explained the structure of the country-by-country report and mentioned that the OECD supports its effective use by publishing guides and organizing international workshops. He presented examples from Malaysia and Indonesia, both of which introduced the concept of country-by-country reporting in 2016 and began exchanging information with other jurisdictions in 2019 and 2018, respectively. He specifically highlighted that Indonesia still faces challenges, as the completion of the report is free-text based, which can result in numerical and computational errors and omissions.

Mayra Lucas then delivered a lecture on transfer pricing documentation, introducing the master file and local file, which are required under BEPS Action 13. She explained that the master file contains essential information about a multinational company (such as its organizational structure, business activities, and intangible assets), while the local file is used to assess compliance with transfer pricing guidelines. She cited Australia and Poland as examples of countries that have made the submission of these files mandatory, which has played an important role in preventing tax avoidance and improving tax transparency. Lucas explained that these documentation requirements enable tax authorities to review companies' tax returns and transfer pricing arrangements, providing a crucial basis for raising tax revenue and enhancing international tax cooperation.

On Day 2, November 20, Nicole Casey gave a lecture on the implementation of country-by-country reports and the peer review process. She addressed challenges faced by countries and shared successes in country-by-country reporting. Following her presentation, Lloyd Garrochinho discussed the confidentiality of automated information exchange in relation to maintaining security. Casey explained that the OECD plays a pivotal role in addressing global tax avoidance by promoting international tax cooperation through the implementation of BEPS Action 13. She added that the OECD encourages countries to exchange information with each other, while the OECD secretariat supports tax authorities by providing model legislative proposals and answering inquiries. As examples of success, she cited Azerbaijan and Georgia, which have worked with the OECD to align their systems with international tax law and improve their information security and analytical capabilities.

Lloyd Garrochinho further discussed the legislation, information exchange, and facilitation required to ensure multinational companies file accurate and timely country-by-country reports, in line with the minimum standards of BEPS Action 13. He also addressed the importance of maintaining confidentiality in automated information exchange systems.

On Day 3, Mark Scott introduced the concept and use of the Common Transmission System (CTS), and Matthew Coakley presented on the development and procurement of IT systems, including the Tax Risk Evaluation and Assessment Tool (TREAT), a tax assessment and analysis tool. Scott explained that the CTS provides a secure and efficient way to exchange tax information, including country-by-country reports, in compliance with BEPS Action 13. He highlighted that the CTS enables automated information exchange, enhances security, and ensures international compliance, contributing to the fight against tax avoidance and the promotion of tax transparency.

Matthew Coakley discussed the need for IT systems to facilitate the exchange of country-by-country reports, as required by BEPS Action 13. He outlined five steps for utilizing these reports and explained that countries can either purchase third-party systems, build in-house systems, or handle individual elements manually. He provided an example of the Maldives, which has successfully implemented a CTS-related system that serves as critical infrastructure for international tax data exchange, enabling effective implementation of BEPS Action 13 and enhancing security and efficiency between tax authorities.

Coakley also introduced the Tax Risk Evaluation and Assessment Tool (TREAT), explaining how it helps assess tax risk, supports tax audits, and determines whether a multinational's tax strategy is legal and appropriate, which is essential for preventing tax avoidance. He noted that TREAT contributes to enhancing international tax cooperation and compliance, improving the efficiency and accuracy of tax audits.

The workshop was significant in that it provided practical, hands-on knowledge and valuable insights into the effective utilization of country-by-country reports, a minimum standard under BEPS Action 13. Participants gained firsthand knowledge through the instructors’ explanations and examples from various countries, which they could apply when designing and implementing systems in their own countries. The workshop also offered essential guidance for tax authorities and businesses to improve tax transparency, manage tax avoidance, and foster more sophisticated and effective tax audits and tax risk management through the proper use of tools like country-by-country reports.

In a follow-up satisfaction evaluation, regarding the overall content, all participants rated it as “good” or “outstanding” (41% good, 59% outstanding). They stated that the information provided by the speakers was up-to-date (100%). Most participants noted that the interaction between speakers and participants was sufficient and that the course helped increase their knowledge in the area. Several participants commented that they were highly satisfied with the content of the course and the communication with the instructors. They also praised the smooth delivery of the course, both content-wise and technically, and appreciated that the course was delivered in multiple languages.