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Limited information

CbCR statistics do not contain information about items such
as intangible assets (e.g., patents, trademarks), liabilities,
intragroup interest and royalty payments, or tax bases that
might be useful for BEPS analysis.

Financial years covered

Anonymous and aggregated CbCR data for 2016, published
in the second edition of Corporate Tax Statistics, have been
compiled for fiscal years beginning January 1, 2016 to
July 1, 2016. Thus, comparability between 2016 and 2017
(which covers CbCRs with fiscal years ending between 1
January 2017 and 31 December 2017) data is limited and
some CbCR data may be included in both periods.

Aggregated data

Aggregated data has a limiting effect as it reduces the detail
of the data and hides the effects of possible outliers.

Tax-exempt groups

Tax-exempt MNE groups and entities within a tax-exempt
MNE group are generally included in the CbCR statistics in
countries where they are not specifically excluded from the
statistics. The inclusion of tax-exempt organizations and MNE
groups affects the analysis of aggregated data because they
usually have revenue, profit/loss amounts, and employees
but no taxes paid or accrued.

The publication of anonymous and aggregated CbCR data
provides an important new source of data on MNEs and their
global activities. The scope and quality of this new dataset
is expected to increase in future periods as MNEs improve
the consistency of their reporting and countries improve
the consistency of their data collection practices, as more
countries provide data, and as issues related to the early
years of data collection are addressed.

While implementation of measures designed to combat
BEPS has advanced strongly since 2017, these data provide
motivation for the need to continue to address remaining
BEPS issues through multilateral action. Furthermore, these
data highlight the need to strengthen CbCR data in the years
to come to further assist the international community in
continuing to measure and monitor BEPS and in advancing
the international tax agenda.

Explanations in this article reflect the writer's personal view on the
matter. EY and/or Kuzey YMM ve Bağımsız Denetim A.Ş. disclaim any
responsibility in respect of the information and explanations in the
article. Please be advised to first receive professional assistance from
the related experts before initiating an application regarding a specific
matter, since the legislation is changed frequently and is open to different
interpretations.

8 December 2021 Aralık 2021