With the release of the OECD’s final package of recommendations to tackle base erosion and profit shifting (BEPS), the focus now shifts to the manner in which national authorities take up, and implement, the measures outlined. Country-by-country reporting (CbCR) implementation has already begun in a number of countries, including Germany, and use of the reporting method is set to be expanded next year.
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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
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches