The increased diversification of the digitised economy presents a major challenge for BEPS initiatives. Lack of a permanent establishment (PE) had led to debate over where tax should be applied, even where a digital entity is not practising a tax avoidance strategy. The prospect of amended tax legislation to address this has raised concerns over the increased risk of double taxation, and a regulatory burden on multinationals.
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Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model