As has been shown by the recent work from the Organisation for Economic Cooperation and Development (OECD) on Base Erosion and Profit Shifting (BEPS), the question of how to tax multinational enterprises in the modern, digitally connected world is extremely complex. Large businesses now operate on a global basis, yet they are taxed by countries whose boundaries have largely been determined by various accidents of politics, history and geography. How to reconcile the global footprint of a modern business with the fiscal rights and obligations of separate tax jurisdictions is at the heart of country-by-country reporting (CbCR). A number of different approaches to CbCR have been taken, but in essence it is the reporting by a business of