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.
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