BEPS 13: CBCR – Country-by-Country Reporting

Jadwiga Glumińska-Pawlic, Hanna Szarpak


In order to eradicate the unfair competition in the form of tax avoidance and profit shifting, the OECD and the EU advise undertaking effective measures, which have been gathered in a complex of 15 actions that should be introduced by member states to their law orders. Promoting the automatic information exchange and reporting (BEPS 13) has become one of the priorities, as it is considered a tool that guarantees the transparency of actions and the future European and international standards in tax matters. Due to the fact that groups of multinational enterprises have the possibility for applying practices of aggressive tax planning, tax organs of member states need extensive and accurate data that will enable them to react to harmful tax practices by introducing amendments to law or implementing appropriate risk assessments and tax inspections. A greater transparency towards tax organs ought to result in multinational tax organs refraining from the practices they have implemented so far, so that they would start to pay taxes in the country they generate income.


optimisation; tax avoidance; profit shifting; base erosion; exchange of information


Country-by-Country Reporting Jurisdiction Status Table, [access: 12.10.2017].

Decree of the Minister of Development and Finance of 13 June 2017 on the specific scope of data provided for in the information on groups of entities and the form of completion thereof (Journal of Laws 2017, Item 1176).

Multilateral Competent Authority Agreement (MCAA), [access: 06.07.2017].

The Act of 9 March 2017 on Tax Information Exchange with Other Countries (Journal of Laws 2017, Item 648).

The Corporate Income Tax Act of 15 February 1992 (Journal of Laws 2016, Item 1888 as amended).

The Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (OJ L 146/8 of 3 June 2016, PL).

Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report, OECD, 05.102015, [access: 15.10.2017].

Data publikacji: 2018-06-28 19:25:41
Data złożenia artykułu: 2018-02-14 22:20:15


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