An approach to BEPS risk assessment: Applying data analytics techniques to country-by-country reporting data

Authors: Julia Maria Martinez Tapia, Nupur Jalan

This article discusses the application of data analytics techniques on data provided by multinationals in
the country-by-country reporting to analyse, interpret and understand financial and other data with ease.
Thus, it would provide a better understanding of multinationals’ global structures, economic activities
and footprints to identify the material risk areas, thereby providing multinationals and tax authorities
with a technique to undertake preliminary base erosion and profit shifting risk assessment. The authors
have primarily relied on the tax risk indicators laid down in the OECD Handbook on Effective Tax Risk
Assessment to build different stages of risk assessment. The possibility and the advantages of setting
up a unified risk assessment tool based on the various risk assessment are also briefly discussed. The
authors believe that such a tool, when publicly available, would enable different stakeholders to interpret
the available data in country-by-country reporting more uniformly and requisite, timely action can be taken to address the identified risk areas.

For full article refer: J. Martinez Tapia & N. Jalan, An Approach to BEPS Risk Assessment: Applying Data Analytics Techniques to Country-by-Country Reporting Data, 29 Intl. Transfer Pricing J. 2 (2022),


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