The Handbook on Effective Tax Risk Assessment explores how information contained in CbC reports can be used for risk assessment and which types of tax risk indicators that may be identified using the information contained in CbC Reports. In chapter 4 some of the main tax risk indicators that may be identified using CbC Reports are described: The footprint of a group in a particular jurisdiction A group’s activities in a jurisdiction are limited to those that pose less risk There is a high value or high proportion of related party revenues in a particular jurisdiction The results in a jurisdiction deviate from potential comparable The results in a jurisdiction do not reflect market trends There are jurisdictions with significant profits but little substantial activity There are jurisdictions with significant profits but low levels of tax accrued There are jurisdictions with significant activities but low levels of profit (or losses) A group has activities in jurisdictions which pose a BEPS risk A group has mobile activities located in jurisdictions where the group pays a lower rate or level of tax There have been changes in a group’s structure, including the location of assets Intellectual property (IP) is separated from related activities within a group A group has marketing entities located in jurisdictions outside its key markets A group has procurement entities located in jurisdictions outside its key manufacturing locations Income tax paid is consistently lower than income tax accrued A group includes dual resident entities A group includes entities with no tax residence A group discloses stateless revenues Information in a group’s CbC Report does not correspond with information previously provided by a constituent entity According to the OECD, combiantions of thise 19 indicators can provide a general overview of the main tax risks of a MNE Group ...