Exploring the Role of BEPS Action 13 in Enhancing Tax Transparency: Joint Insights from Tax Authorities and Statutory Auditors in Multinational Enterprises.

Abstract

Global concern over corporate tax avoidance has intensified in recent years, prompting reforms such as the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13, which introduced a standardized three-tiered documentation system, the Master File, Local File, and Country-by-Country Report (CbCR), to enhance tax transparency and support risk-based enforcement. This thesis investigates how BEPS Action 13 operates in practice within Belgium, focusing on two key institutional actors: tax authorities and statutory auditors. The central question asks how these actors interpret and apply BEPS documentation, and what this reveals about the framework’s effectiveness in promoting substantive transparency.

Using a qualitative research design, the study draws on nine semi-structured interviews with Belgian tax officials and auditors, analyzed through thematic analysis to identify patterns in documentation use, institutional coordination, and operational challenges. Findings reveal that tax authorities actively use BEPS documentation, particularly CbCR, within the Transfer Pricing Audit Cell (TPAC) to identify high-risk cases and target audits, while statutory auditors engage with the Master and Local Files mainly as contextual references when evaluating tax-related disclosures under IFRS and ISA standards. Auditors’ access to CbCR is minimal, limiting its role in financial audit processes. A notable gap exists in coordination between the two institutions, with each operating in isolation despite overlapping objectives in corporate tax oversight.

These results suggest that while BEPS Action 13 has strengthened transparency, its impact on enforcement is constrained by limited inter-institutional integration, uneven data access, and varying interpretive practices. Policy implications include the need for greater standardization and digitalization of reporting, targeted capacity building, and structured information-sharing mechanisms between tax authorities and auditors, subject to confidentiality safeguards. Overall, the Belgian case illustrates that achieving the governance potential of BEPS Action 13 requires moving beyond formal compliance toward a collaborative, data-driven approach to corporate tax oversight.