OECD: Aggregated country-by-country reporting data

Report covering over 160 countries and jurisdictions that includes new aggregated CbC reporting data on the activities of almost 7,000 MNEs

Report covering over 160 countries and jurisdictions

The Organisation for Economic Cooperation and Development (OECD) today issued the latest annual Corporate Tax Statistics [PDF 3.77 MB] (56 pages), a report covering over 160 countries and jurisdictions that includes new aggregated country-by-country (CbC) reporting data on the activities of almost 7,000 multinational enterprises (MNEs).

As explained in the accompanying OECD release:

  • The new CbC reporting data shows that the median value of revenues per employee in jurisdictions with a corporate income tax (CIT) rate of zero is U.S. $2 million as compared to just U.S. $300,000 for jurisdictions with a CIT rate above zero. Moreover, in investment hubs, related party revenues account for 35% of total revenues, whereas the average share of related party revenues in high, middle and low income jurisdictions is around 15%. While these effects could reflect some commercial considerations, they are also likely to indicate the existence of base erosion and profit shifting (BEPS).
  • The data released today also show that the CIT remains an important source of revenue for most countries, especially for developing and emerging market economies. On average, the CIT accounts for a higher share of total taxes in Africa (18.8%), Asia and Pacific (18.2%) and in Latin America and the Caribbean (15.8%) than in OECD countries (9.6%).
  • After decades of cuts to statutory CIT rates, the new data point to a stabilization of CIT rates in 2022 with some narrowing of tax bases in 2021, as countries sought to strike a balance between raising revenue and incentivizing investment. The stabilization of CIT rates may also be a response to the fiscal challenges faced by governments in the wake of the coronavirus (COVID-19) pandemic. The average combined (central and sub-central government) statutory tax rate for all jurisdictions covered in the dataset was 20% in 2022, compared to 20% in 2021 and 28% in 2000.
  • There is some evidence that governments have used the CIT system to try to boost economic recovery, by incentivizing investment, especially in research and development (R&D). The data point to a narrowing of corporate tax bases, driven by more generous capital allowances, with these provisions being used in 65 jurisdictions in 2021, up from 57 in 2019. The data also suggest an increase in the generosity of R&D tax provisions in 2020 and 2021 in a number of OECD countries and EU member states following the outbreak of the coronavirus (COVID-19) crisis.
  • Next year’s edition of Corporate Tax Statistics will include two years of new CbC reporting data.  

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.