One of the most tangible outcomes of the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) project and the associated scrutiny of business taxation is that the corporate tax transparency environment is undergoing a transformational change.
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Absolutely core to this new era of transparency is that information shared with one tax authority will now be rapidly available to all others. This means that the multi-jurisdictional, multiyear impacts of any structure or transaction should be considered more carefully — both moving forward and looking back, because tax authorities will certainly be seeking to use the new data to retrospectively identify and study cases of perceived avoidance from recent years.