OECD CbCR Data Reveal Persistent BEPS Practices in 2022

The OECD released aggregate Country‑by‑Country Reporting (CbCR) data that reveal ongoing base erosion and profit shifting (BEPS) by multinational corporations in 2022. The figures appear in the Corporate Tax Statistics 2025 and highlight a mismatch between profit locations and economic activity.

Eighteen percent of total profit was booked in investment hubs, yet only four percent of employees and twelve percent of tangible assets were located there. The median revenue per employee in those hubs reached US$1.72 million, far above the median in high‑income (US$460 k), middle‑income (US$245 k) and low‑income (US$170 k) countries. CbCR is a transfer‑pricing document required when a group’s consolidated turnover exceeds €750 million (about Rp11 trillion).

The findings confirm that BEPS practices remain significant, although the revenue‑per‑employee ratio in investment hubs has fallen from US$1.78 million in 2017. The decline may reflect recent economic turbulence, but the data continue to serve as a key indicator for tax authorities to strengthen anti‑avoidance measures.