The Brockman brief: Audit and risk transparency: Why it matters

February 01 2016

‘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.

To unlock this content:

Take a Free Trial or Login

Topics

Portugal Philippines United States Israel Italy Isle of Man Jersey Japan Paraguay Pakistan Slovenia South Africa Singapore Slovak Republic Argentina Global Australia Romania Albania Russia Serbia Algeria Saudi Arabia Monaco Mauritius Mexico Morocco North Macedonia Gibraltar Greece Germany Guernsey Gulf Cooperation Council Malaysia Nigeria New Zealand Feature Norway Hong Kong SAR India Indonesia Hungary Iceland Ireland Netherlands Iran Chile Direct Tax Costa Rica Croatia China Tax Disputes Colombia Compliance Management France Luxembourg Denmark Cyprus Czech Republic European Union Finland Egypt Tanzania Thailand Belgium Austria Spain South Korea Switzerland Taiwan Sweden Venezuela Canada Vietnam Cayman Islands Bosnia and Herzegovina Turkey United Arab Emirates Bulgaria Cambodia Uruguay United Kingdom Brazil Ukraine British Virgin Islands ITR Magazine February 2016 Africa Asia-Pacific Europe Latin America and Caribbean North America Central America Jurisdictions

more across site & shared bottom lb ros

More from across our site

Direct Tax

AI in Tax Forum 2026.JPG

French tax authority leads way in AI adoption

The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard

Ed Conlon, April 29 2026

Direct Tax

pillar two forum 2026 crowd shot.JPG

HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

David Beringer, Sucafina, ITR P2 Forum 2026.JPG

Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026

Direct Tax

India Supreme Court

Tiger Global ruling in India: scope, limits and risks

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax

marc lien resized.jpg

Unity Advisory appoints AI chief as firm hits 100 employees

The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’

Sam Sholli, April 27 2026

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Brazil’s pillar two carve-out request prolongs a death by a thousand cuts

Projected revenue losses and exemption requests are harming the project’s capability and viability

Sam Sholli, April 24 2026

Indirect Tax

Prison

This week in tax: HMRC jails payroll fraudsters for 22 years

HMRC secured lengthy prison sentences in a major payroll VAT fraud case, while law firms announced tax promotions and hires

Tom Baker, April 24 2026

Transfer Pricing

Australian Company Tax Return concept

‘More refined’: advisers dissect updated ATO TP guidance

Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined

Sam Sholli, April 23 2026

Direct Tax

tim zech and jeff soar.png

AI in tax: from early promise to everyday reality

ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London

April 22 2026

Direct Tax

Brazil tax money

Brazil has ‘substantive grounds’ for pillar two carve-out request: advisers

Brazil’s bid to seek US-style exemptions from pillar two is ‘highly advantageous’ for multinationals, ITR has also heard

Sam Sholli, April 22 2026