‘Transparency’ is the latest term of art that has emerged from the OECD’s Action Plan with respect to its base erosion and profit shifting (BEPS) initiatives. But the obvious question that has consciously been ignored in the public domain is: where are the matching transparencies regarding determination of tax risks and identification of substantive issues by tax authorities upon commencement and conduct of an audit?
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment