Profit shifting is more significant for developing countries since their tax revenue relies heavily on corporate income tax. The introduction of CbCR of the OECD/G20 BEPS Project is perceived to enhance transparency for tax administration, expected to help developing countries overcome this problem. However, using CbCR and its information is subject to various conditions and constraints. Calling for the implementation of public CbCR has been persistent further by non-government organizations (NGOs). Public disclosure is hoped to increase transparency and keep aggressive tax planning behind. Several initiatives have applied public disclosure of CbCR. This paper aims to review the current regime of CbCR in Indonesia. It then studies the existing implementation of public CbCR in the European Union as examples of public CbCR in practice. Further, this study discusses the potential benefits, challenges, and risks of public disclosure of the CbCR from the perspectives of developing countries.
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