Expert Analysis

Since its introduction in 2016, the OECD’s project to combat base erosion and profit shifting (BEPS) has changed the environment for tax audits around the world. Corporations and heads of tax have to adapt, says Sandy Markwick, head of the Tax Director Network (TDN) at Winmark.

It may seem like an odd question for an international tax journal to ask, but the OECD’s report on its programme of work on digital tax indicates that we may be at the end of whatever certainty we thought we had about cross-border sales and permanent establishments, writes Giles Parsons.

The OECD has been forced to question its own assumptions since the high-tech sector destabilised the international tax system. Taxpayers fear this shift will herald radical change, writes Josh White.

Kapil Sethi and Mithilesh Reddy of Steadfast Business Consulting examine why financial transactions remain a transfer pricing battleground six years after the OECD’s Chapter X guidance, and what taxpayers should do about it

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Rob van der Woude of Fonoa argues that AI will not reduce tax work but transform it, making connected data infrastructure the foundation of compliance and competitive advantage

Simón Somohano, Aranzazú Estrada, and Mario Coyoy of Deloitte explore the shift towards risk-based transfer pricing audits in Mexico and Central America and suggest how multinationals can move from a documentation-centred approach towards a broader model

Deloitte tax partners examine how tax authorities in Colombia, Peru, Ecuador, and Venezuela are shifting transfer pricing audits from pricing analysis to economic substance and evidentiary support

Silvana Blanco, Joel Morante, and Felipe Prado of Deloitte examine how transfer pricing is being reshaped in Argentina, Chile, and Uruguay through closer scrutiny of governance, value creation, operating models, and pillar two implications

Charles Setia Oetomo and Arip Prastyo Wibowo of GNV Consulting outline Indonesia’s new rules on tax representatives and explain a fresh VAT collection mechanism for cross-border digital transactions

Susana Estêvão Gonçalves of Pérez-Llorca analyses how the decision restricts Portugal’s real estate transfer tax and may affect similar regimes across the EU

Jakub Warnieło and Agnieszka Walska of MDDP outline the tax risks attracting the greatest scrutiny in Poland and explain how foreign investors can reduce audit exposure through proactive compliance