What Is Country by Country Reporting? (Part 2)
03.18.2022 | Duration: 09:50
Exploring Transfer Pricing Episode 03-2022 | With the onset of public country-by-country reporting - coordination, transparency, and analysis is key. Learn about some of the risks and mitigation tools and practices associated with interpreting data.

Podcast overview
Country-by-country (CbyC) reporting was developed as part of the OECD's Inclusive Framework of Base Erosion and Profit Shifting. Transparency and coordination continue to lead the way as we go beyond the forms to understand some current implications of increased adoption of CbyC reporting.
Why are these implications important? Because CbyC reporting rules and requirements are pervasive, and expanding.
As of the publication of this episode:
- Over 80 percent of the countries that have implemented final rules on CbyC requirements require CbyC notifications
- More than 65 percent of the countries that require CbyC notifications have CbyC notification penalties
- Just over 90 percent of the countries that have implemented final rules on CbyC requirements have penalties associated with the CbyC report
In this episode, our host Brittany Hardin Tanguay speaks with Sean Foley, Global Head of Dispute Resolution and Principal with the KPMG Washington National Tax group, and John DerOhanesian, International Tax Managing Director with the KPMG Washington National Tax group, to continue their exploration of country-by-country reporting and its impact, and discuss the KPMG CbyC Risk Analyzer and other benchmarking and risk assessment tools.
Meet our podcast team


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