A fundamental sticking-point of country-by-country reporting (CbCR) is that companies’ tax affairs could be published in the public sphere. This is causing a great deal of distress for multinationals concerned about confidentiality and competition. There is consequently a big debate about how to comply and whether companies should comply at all.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties