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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A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
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
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
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
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