In a recently published report from the UK Parliament Select Committee on Statutory Instruments, the Committee questions whether HMRC has the authority to enforce the anti-avoidance regulation (regulation 21) included in the final Country-by-Country (CbC) reporting regulations issued on 26 February 2016 ({News-2016-02-29/A/2- previous coverage}). Regulation 21 includes that if a person enters into any arrangements with the main purpose, or one of the main purposes, to avoid any obligation under the CbC regulations, the regulations will have effect as if the arrangements had not been entered into. Such anti-avoidance rules are not part of the OECD Action 13 guidance....