Expert Analysis

Alberto Benshimol

1675 Broadway

Joel Williamson, Charles Triplett and Jason Osborn of Mayer Brown On February 12 2013, the OECD published its report on Addressing Base Erosion and Profit Shifting (the BEPS report). The BEPS project is remarkable due to its backing by the political leaders of the world's largest economies. It was commissioned by the G20 in 2012 as these governments scramble to preserve and recover corporate tax revenue, which declined sharply during the down economy years, from 3.8% of OECD members' combined GDP in 2007, to 2.9% of GDP in 2010. Beginning with the bold statement that "[b]ase erosion constitutes a serious risk to tax revenues, tax sovereignty and tax fairness for OECD member countries and non-member countries alike," the BEPS report identifies a number of key pressure areas where multilateral action may be needed. These include:

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks

The regime has modernised the taxation of employee equity, but several lingering shortcomings leave room for enhancement, say João Riscado Rapoula, Miguel Gonzalez Amado, and Ana Francisca Ribeiro of VdA

Sandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions