Podcast: Baker McKenzie partner predicts AI audits and pillar two disputes

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Podcast: Baker McKenzie partner predicts AI audits and pillar two disputes

ariane calloud baker mckenzie podcast article image

AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud

Tax authorities are becoming more sophisticated, more data-driven and increasingly willing to scrutinise the reality behind multinational operating models, according to Ariane Calloud, a partner in Baker McKenzie's Paris tax dispute resolution practice.

Speaking on the latest episode of Taxing Times with ITR, Calloud discussed how growing volumes of data, international information sharing and advances in AI are transforming tax audits and controversy work.

In France, she said, transfer pricing (TP) remains a key focus, with authorities increasingly examining whether business operations, decision-making and value creation activities align with groups' transfer pricing policies.

The conversation also explored how multinationals can reduce controversy risk before disputes arise. Calloud stressed the importance of understanding how local operations function in practice, regularly reviewing TP arrangements and ensuring consistency between tax positions and public-facing information.

Looking ahead, Calloud predicted that tax authorities will continue to coordinate more closely across borders through simultaneous and joint audits. She also identified pillar two as a likely future source of controversy as administrations gain experience with the rules.

We hope you enjoy listening.

more across site & shared bottom lb ros

More from across our site

As funds work becomes more complex, Proskauer is betting that embedded tax expertise can strengthen its wider offering
The recently founded AI platform stands out in a crowded marketplace thanks to a compelling vision and friends in the right places
Advisers expect consumption tax reform to stay on course, but debt pressures could push the government towards tougher enforcement and incentive reviews
The firm demonstrated its sweet spot of litigation with an international twist with the recent win for the Danish tax authority…but it’s not a tax case
The recently formed firm has taken a break from hiring EY talent to expand its transactional tax and tax technology capabilities
The AI platform, founded last year by two school friends, is partnering with challenger firms like Unity Advisory and A&M Tax to launch its own assault on the AI tax market
Not only has Aurtus received recognition from ITR in the past, but its founder was both a partner at KPMG and co-founder of Dhruva Advisors
Clients care more about considered counsel than rapid media-friendly soundbites, says Matthew Gilleard, associate director at Infinite
It was also a memorable night for Galicia, KPMG, Skadden and Pinheiro Neto, all of which scooped major awards at a gala ceremony in New York
The former Deloitte UK CEO earned a 45% raise in a year when 1,000 staff reportedly lost their jobs – and the pay gap is only getting bigger
Gift this article