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How transparency is transforming the global tax landscape
In this episode of the Tax and Law in Focus podcast, speakers explore how transparency rules, international cooperation and artificial intelligence (AI) are reshaping the tax function.
In this episode of the Tax and Law in Focus podcast, host Susannah Streeter is joined by Aruna Kalyanam, EY Global and Americas Tax Policy Leader, Jose Murillo, EY Americas International Tax and Transaction Services Leader and Manal Corwin, Director, OECD Centre for Tax Policy and Administration to explore how transparency is reshaping the global tax environment. Over the past two decades, transparency initiatives have transformed the expectations on taxpayers and tax authorities alike.
The panel traces the origins of this transformation — from post-financial crisis reforms and the OECD’s BEPS framework, to real-time reporting standards and automatic exchange of information. They also examine how governments are using transparency to close tax gaps, reduce controversy and strengthen compliance frameworks.
But transparency isn’t just about enforcement. Today’s forward-looking tax leaders are using disclosure to build trust, demonstrate good governance and align with corporate ESG goals. The discussion explores how tax functions are evolving — becoming more integrated across business operations, sustainability and strategy.
The episode also looks ahead to how technologies like generative AI (GenAI) are accelerating change. As tax authorities and corporations alike adopt new tools, data quality, governance and predictive insights will become key sources of advantage.
Whether you’re a tax leader navigating compliance or a policy maker shaping the future, this episode offers timely insights into how transparency is reframing global tax behavior and business accountability.
Key takeaways:
Understand how global transparency initiatives have redefined tax disclosure and enforcement
Learn how BEPS, FATCA and automatic exchange of information are shaping today’s reporting standards
Discover how tax functions are evolving through AI, data governance and cross-functional collaboration
Explore the benefits of transparency as a strategic asset—not just a compliance obligation
Gain insight into how global cooperation is limiting controversy and boosting voluntary compliance
For your convenience, full text transcript of this podcast is also available.
Susannah Streeter
Hello and welcome to the EY Tax and Law in Focus podcast. I'm your host, Streeter. The last 15 years has seen a focus on the need for more transparency for governments to enforce their tax rules. This has unfolded in respect of transparency of individuals and also corporate behavior. The global tax transparency drive, propelled by sustained collective action by the world's governments, has raised the stakes for businesses. They have redefined international tax practices. Taxpayers don't just have to comply with myriad transparency laws. They find themselves accountable to a much wider variety of stakeholders than a decade ago. And they're facing heightened data demands in scrutiny, requiring advanced data management and technology implementation to meet compliance standards. The arrival of GenAI can be another game changer. On one hand, equipping tax authorities with greater powers of oversight, but also giving tax functions the potential to vastly improve accuracy, efficiency and collaboration to meet the new demands. So in this edition, we're going to focus on how tax and law leaders can deal with these changes. We can look at what's happening in individual jurisdictions, as well as some of the efforts made by multinational bodies. We'll also find out how companies can stay agile for what the future looks set to bring. I'm pleased to say I'm going to be joined by a panel of subject matter experts who will share their insights. But before I introduce them, please do remember, conversations during this podcast should not be relied on as accounting, legal, investment, nor other professional advice. Listeners must, of course, consult their own advisors. But now, without further ado, please do welcome Kalyanam, who's the EY Global and America's Tax Policy Leader. Hello there, Aruna. Where are you today?
Aruna Kalyanam
Hi, Susannah. It's great to be here. I'm joining you from beautiful, sunny Washington, DC.
Streeter
Fantastic. Great to have you with us. Let's introduce as well, Murillo, who is the EY America's International Tax and Transactions Services Leader. Jose, great to have you with us. Where are you speaking to us from?
Jose Murillo
Hi, Susannah. I am also in Washington, DC, today.
Streeter
Just down the block, perhaps. Also, Corwin, who's the Director of the Centre for Tax Policy and Administration at the OECD. Manal, it's really great to have you here and to hear your insights. Where are you speaking to us from?
Manal Corwin
Hi, Susannah. My pleasure to be here, and I am in Paris.
Streeter
Fantastic. Well, I'm in Bristol in the UK, so we have a real international flavor to this podcast today. But first, let's set the scene and look at what's prompted this big global push for tax transparency and spark the redefinition of tax practices. Jose, where did this start? I mean, there were a lot of headlines around the turn of the century, weren't there? About widespread tax avoidance and secrecy. But are there also links with the global financial crisis and the need for governments to effectively replenish their depleted finances to prop up economies?
Murillo
Yeah, thanks, Susannah. You know, this effort evolved over, I would say, a 20-plus year period as the focus around the world increased on the tax gap, especially here in the United States, and tax avoidance just more generally. You mentioned links to the financial crisis and the need for governments to replenish and have more resources to make investments. I think that was part of it. As a result of that, many jurisdictions began enacting their own domestic legislation requiring increased reporting, increased transparency that results in greater collections, whether on audit or on the front-end. Then there were also other external stakeholders, NGOs, demanding greater disclosure by companies of where they're earning their income and paying taxes. It's been a process evolving over several decades.
Streeter
A collision of forces, really. Manal, the OECD has played a leading role in pushing this forward. Can you explain what the organization did and just how this came about?
Corwin
Indeed, the OECD has played a pivotal role in advancing transparency amongst governments. The OECD itself serves as a platform for collaboration where countries can share common concerns that are best addressed through cooperation and collective action. Often, those shared concerns are driven by external events. I think Jose did a nice job of giving an overall atmosphere. I think in the area of transparency, there were really two specific external circumstances that serve as the impetus for separate initiatives and new transparency standards. The first was this growing concern about bank secrecy, prompted by several high-profile cases and the role it played to enable tax evasion among individuals. Then the second was fueled by the financial crisis, as Jose mentioned, and you mentioned, where there was a growing concern that outdated international standards relating to corporate taxation, along with the absence of information, was exacerbating proper shifting and eroding tax bases. If I just take those one at a time, in the case of bank secrecy, I think spurred by that shared concern and to a great extent by the US adoption of FATCA, the international community building on the experience with FATCA adopted a common reporting standard on exchange of financial account information. That standard has now been widely adopted. It went from 49 jurisdictions to around 120 jurisdictions now adopting. In the area of corporate transparency, so relating to this BEPS initiative, that second area, where there was more cooperation, of the 15 BEPS action items, four were minimum standards, and two of those standards related to transparency. So first, Action 5, which requires the spontaneous exchange of information on tax rulings that may create BEPS risks. And then the second was Action 13, which requires the collection and reporting of country-by-country information, as well as the exchange of those reports for multinational groups with consolidated revenue over €715 million. Both of those areas and you can see, really, those external circumstances, drove international standards that were game-changing in the transparency landscape.
Streeter
An awful lot of developments for firms to get their heads around. Aruna, what kinds of deep-rooted questions did this push for transformation trigger for companies, or do you think this, in some ways, was already happening? Was there already a transformation taking place?
Kalyanam
Well, Susannah, companies in a tale as old as time, have been balancing their compliance obligations alongside their obligations to create value. But I think in this next era of transparency, these two obligations that sit side by side have driven a movement to use business information in a beneficial way, not just in a way that is satisfying requirements. In my mind, this has demonstrated the asymmetries in transparency. So where companies were once in the habit of being somewhat secretive and not sharing this knowledge, they're really seeing an opportunity in how to use this information and create a very good public image for themselves. At the end of the day, the world is one where data is fully a commodity, and data affirmatively has value. So as companies are adapting to this new mindset and thinking about how they can be more public with their information, we're seeing trends of more disclosure and more transparency.
Streeter
So there's a whole process of adaptation going on. Manal, just how successful has the global forum been in terms of a revenue raiser?
Corwin
Well, the Global Forum on Transparency and Exchange of Information was established in the year 2000, and then it was restructured in 2009 to ensure the consistent implementation of the international standards on exchange of information. It related to that first transparency that I referenced earlier to addressing bank secrecy, but wasn't involved with the implementation of the BEPS transparency standards. But with regard to the exchange of information, the Global Forum, which is now 170 jurisdictions, 23 observers, was tasked mainly with monitoring the implementation of those standards, the exchange of information standards through peer review processes and monitoring, as well as capacity building. That work has enabled tax administrations to identify more than €130 billion to date of additional revenues, including tax interest and penalties, since 2009. That obviously is tied to the greater transparency standards. In particular, the widespread adoption of automatic exchange of information has increased voluntary compliance, as well as improved the investigative outcomes of tax administrators in terms of being able to identify revenues available for collection.
Streeter
So yeah Manal, you're talking there about the role of tax experts. Jose, to what extent has this emphasis on tax transparency really increased the profile of the tax function?
Murillo
Well, Susannah, I think just the increased disclosure and transparency by itself increased the profile of the tax function, given the risk of improper disclosure and/or inaccurate data. There are more stakeholders focusing on those disclosures, on the data that increase the profile just within organizations, the C-suite is paying closer attention to the tax function and what is being reported. You've got more external stakeholders, government taxing authorities, NGOs, et cetera. So much higher-profile tax has a bigger seat at the table these days.
Streeter
And Aruna, how has the role of tax departments within businesses had to transform as a result of all of this?
Kalyanam
I think many of the tax professionals who are listening to this podcast would agree that the tax function has simply just moved far beyond the role of ensuring proper and adequate revenue remittance. We're seeing a greater complexity in tax law, and we're seeing greater global trends of providing incentives through the tax code rather than through direct spending. This means the tax department as a whole has a greater role and plays a key critical component in corporate governance. The way I think about it, the VP of Tax is no longer just reporting to the CFO, the tax department is collaborating with the operations department, with the sustainability department, and so on and so on. That VP of tax is demonstrating a business's good judgment in their tax record and demonstrating the business's stewardship of their role in a community.
Streeter
Manal, what role would you say the international cooperation has played in all of this? I mean, to what extent are jurisdictions really collaborating now in terms of sharing information, but also enforcement. What kind of changes are we seeing?
Corwin
There's been a huge acceleration and increase in the amount of collaboration and the robustness of the collaboration among governments. Just to give you a sense in the area of exchange of on financial accounts. Back in 2009, there were barely any exchange relationships. The network of exchange agreements was quite limited. Today, there are over 9,000 bilateral relationships in place. As of 2023, there was information on over 134 million financial accounts that was exchanged, covering total assets of €12 trillion. As a result, the enforcement challenges associated with bank secrecy have really been eradicated for the most part. In the area of BEPS and the transparency there, we have under Action 5, there are more than 58,000 exchanges of tax rulings that have taken place among jurisdictions, whereas before there were hardly any other than on request. And under BEPS Action 13, which involved the exchange of country-by-country reports, we have over 4,100 bilateral relationships that have been established to facilitate the exchange of those country-by-country reports among over 100 inclusive framework members. So quite a significant increase in acceleration of collaboration among jurisdictions to enforce their tax rules.
Streeter
Absolutely. There's a huge number of bilateral relationships being built up. So, Jose, as we see better trust being established through governance programs between taxpayers and tax authorities due to this increased transparency. Is it leading to fewer interventions in some jurisdictions, do you think?
Murillo
I do think it is. I think greater transparency disclosure changes behavior. So there are just fewer instances for tax authorities to intervene and do audits. But more generally, I would say it's always in the interest of taxpayers and tax authorities to better manage and minimize tax controversy. This has led to an increase in the use of formal channels to manage controversy on the front-end, especially, for example, advanced pricing arrangements, whether it's full disclosure of facts, expectations and negotiation between taxpayers and the government, and also the greater use of real-time audit programs like the Compliance Assurance Process, the CAP, here in the United States for large corporate taxpayers, or the international CAP that large multinationals can use to engage with multiple jurisdictions in which they have business activities. These programs are all designed to minimize controversy and provide more certainty, which, again, is in the interest of taxpayers and taxing authorities, and it very much, I think, has been an outgrowth of this increased transparency and disclosure.
Streeter
It certainly is. Manal, you talked just now about this explosion in the number of relationships. How do you view this changing relationship between tax authorities and taxpayers? Would you say there is now much more voluntary compliance and also a sense of more fairness spreading?
Corwin
I think so. First of all, I think that the relationship between the tax authorities and taxpayers is as important, if not more important, than the relationship between tax authorities. I agree with Jose that we've seen improvements there. I think the work at the OECD, we've done work on tax morale in particular, which has highlighted this critical importance of trust between tax authorities and taxpayers and its effect, its positive effect on tax compliance and the role of transparency in building that trust. I think that the responsibility for building that trust rests with both the taxpayer and tax administrations. The increasing cooperative compliance, I think, is an outcrop of our ability to not only have consistent transparency standards, but that sense of fairness, as well as the clear policies around what's expected. Then finally, I'll mention that I think improving tax certainty is also critically important to building trust. I think there what we mean consistency of rules, consistency of administration actions. One of the BEPS action items, Action 14, was very, very focused on strengthening, for example, effective dispute resolution and ensuring access to dispute resolution for taxpayers and peer-reviewing jurisdictions to make sure that their practices in dispute prevention and resolution are reliable. I think all in all, there is a net positive effect, but it's an area where we can always continue to do more work.
Streeter
And Aruna, what's your take on this? What changes are you seeing on the regulatory scene?
Kalyanam
First, I would agree with Manal and Jose. Everyone wins when tax controversy is minimized. A big part of that success comes from ensuring that there's trust between the tax authorities and taxpayers. I will say, though, that the complexity of tax law has plagued this objective. I think forward-looking in the current and in the future, tax-writing officials worldwide would be well-served by making simplicity a core element of their policy-making. But in addition to that, I think that tax authorities are also going to need to evolve to ensure they're keeping up with new and novel forms of value and methods of value creation. What comes to mind to me is cryptocurrency and NFTs. Digital value creation and how it should be taxed is such a rapidly evolving frontier, and it's going to continue to be an important part of tax authorities' work.
Streeter
It's really interesting you talk about that. I mean, this is all sprung up at a time when we're in this era of such huge technological change. And of course, in this area, we have so much data out there. So, Jose, why is good data management so crucial in a time of greater tax transparency?
Murillo
Just a simple answer. I think your data tells your story. So it's in everyone's interest to have good, reliable data so you can tell a good story.
Streeter
And I suppose as well, you need to tell that story, but you need to make sure it's not muddled up by perhaps your data not being well-managed. So, Aruna, from your point of view, how important is it that you have control over that data?
Kalyanam
I think in the next decades to come, we're going to see data as a resource is going to be like water as a resource. Frankly, it's just critical for businesses to keep their records current and clean. But part of this importance comes from the need to be able to parse data for a variety of purposes. Businesses are going to make huge upfront investments in this space in order to reduce costs over time. But the uses of this data will change and evolve, so it's incumbent on the taxpayer to take the steps that their investments in this space are intentional, regular, and curated to meet those needs.
Streeter
And, Aruna, all these rapid developments also come at a time when there have been budget cuts in the tax function, and we've seen cost pressures rising. How should all of this be navigated? What kinds of opportunities are there out there?
Kalyanam
Susannah, when I was on Capitol Hill, the lawmakers on my committee would argue that a law is only as good as its enforcement will allow it to be. Given the important role that revenue collection agencies play in financing government operations, ensuring that tax laws are properly being enforced and that taxes owed are being collected is nothing short of critical. We've seen the return on investment in revenue agencies is multiples of the dollars that are put in, and there are signals that the Trump administration is envisioning a radically transformed IRS US, from leaner staff to refocusing their priorities within the agency, something that US businesses are going to need to navigate as well.
Streeter
Yes, there's certainly so much to navigate as the different tides swirl around in terms of enforcement and reporting. Jose, this is, of course, all happening as AI tools are being rolled out across the world. Let's focus on this a little bit. I mean, how split would you say companies are in terms of their technological prowess here? What can companies do to speed up, particularly given that governments will also probably make use of GenAI to improve data collection and compliance.
Murillo
Thinking about your earlier question about budget cuts in the tax function, cost pressures. Like today, departments are smaller, but more is asked of them, so they're having to do more with less. And fewer people are coming into the profession, so you can't go out and hire people. You've got to make greater use of technology, generally, and AI in particular, as to where companies are. It depends. Some are pretty advanced and others are catching up, but they're all engaged. They all know that this is the direction of travel.
Streeter
Aruna, how would you say that AI can also help tax teams deal with horizon scanning to allow them to understand the direction of regulatory change in a more joined up and timely manner.
Kalyanam
AI has the potential to be a critical tool in terms of forecasting important elements of how value is moving within a company and can help computation of taxes work in a more accurate and timely manner. But small changes can have a big impact here. Data, both real and now even synthetic data, are going to be incredibly valuable in building the AI models that will do this work.
Streeter
Can you give me any examples of how this could be, Aruna?
Kalyanam
Here at EY, we're just seeing how some of these tools are being developed and how inputting historic aspects of a business's operations, also combining that with synthetic data to mimic some of those operations and give a broader set of data for a large language model to think about interpreting, all of these can put out the right information you need, believe it or not, even with the incorporating synthetic data in a more specified way in terms of forecasting.
Streeter
It's important, isn't it? Highly important. We talk about this so much. We hear it talked about so much, about good data management and the cleanliness of the data, how AI can only really work built on top of really good data. How, actually, can AI be harnessed, though, to help validate and cleanse tax data? Because you can look at this in two ways, can't you, Jose?
Murillo
Yeah, that's a really good question. It is often the case that in any complicated, large data-intensive engagement, the hard part is always finding the data, getting it in good enough shape for it to be usable. That can be 30, 40, 50% of the effort. Use of AI and AI tools, generally, it's still, I would say, early stages. The tools are still evolving. There's a lot of focus, a lot of investment being put into that. As a firm, we're putting a lot of money into it. So there's clearly a hope and expectation that AI will streamline that process and make these projects more efficient. We have a series of tools that can identify discrepancies within a tax return over multiple years, identify opportunities, and tools that, if humans were doing it, would take weeks. AI can do it for us in a matter of minutes. So just speeding up the process, making it more efficient. But it all, to your point, starts with the data on the front-end. If you don't have good data, if it's not usable not manageable, it's going to be a difficult exercise.
Streeter
And of course, as we know, AI technologies are changing so rapidly. They're evolving very fast, and we've just got to keep up with them as they continue at pace. But it's not just AI technology that is evolving fast. Transparency rules have also still been evolving, haven't they? Manal, in terms of the BEPS project, what stage of implementation are we at with this?
Corwin
Well, we're pretty far along, and I do think just going to the prior discussion in terms of the pressure on resources, I think the need for greater transparency is also a matter of efficiency for tax administrations because it allows them to focus on the real risks associated with their effective enforcement as revenue pressures increase. AI is going to feature significantly in tax administration's ability to use the information they get from transparency initiatives. But in terms of the uptake, and again, dividing it in the two areas that we focused on, which is the Common Reporting Standard, there we have over 120 jurisdictions that have committed to the Common Reporting Standard and the crypto asset reporting That is also featuring now where we have 65 jurisdictions have committed to implement the CARF or Crypto Asset Reporting Framework in time to start exchanging that information in 2027. With respect to BEPS specifically, all 147 members, jurisdictions of the Inclusive Framework, have agreed to the two minimum standards on exchanging information with respect to tax rulings as well as to C-by-C reporting. There are at different stages of implementation, including being ready in the case of country-by-country reporting to have the confidentiality rules in place to receive information. But that is going to continue to grow. Then transparency as well as certainty are going to remain key features and important elements of our ongoing work, particularly in the context of the work on the two-pillar solution to address the digitalization of the economy. The need to build in the transparency components and certainty components front and center.
Streeter
Yeah, so a lot still to deal with going forward. Jose, would you say that in some ways this has prompted more concerns in terms of the risks of double taxation as this evolution continues at pace?
Murillo
I think so to some extent. I mean, generally, greater disclosure, the work that the OECD has done, you know, the digitalization of the global economy, I think has caused more jurisdictions to exercise their taxation rights in different ways. So you've got multiple jurisdictions taxing the same income stream with new measures of taxation that always increases the risk of double taxation. And look, each country decides to relieve double taxation differently. That is a general policy of the international tax system, but where there is disagreement between jurisdictions as to who should have the primary right of taxation, very clear risk of double taxation, and it can be a big issue. But I would say the OECD does a great job in addressing that issue. To the extent there is cooperation and collaboration between jurisdictions, it ought to be minimized. It probably can't be eliminated entirely, but it is being managed.
Streeter
Would you say there are other ripple effects of transparency, say, on other corporate objectives like ESG, Environmental and Social Governance?
Murillo
I think so, because I think what has happened with greater transparency and disclosure over the last 20 plus years is a roadmap for other objectives. I think stakeholders will expect the same amount of disclosure, the same amount of transparency going forward. So it's a clear blueprint that can be applied elsewhere.
Streeter
And Aruna, what are the lessons do you think we still need to learn from the first wave of transparency to better equip teams to deal with the second wave of change?
Kalyanam
A phrase that I've heard used, and I want to be very clear in how I articulate this, 'don't be an ask hole'. That is, don't create the... I know, it's pretty good. Don't create the burden of asking for something without an intentional purpose of using it. I think this applies to right-sizing transparency requirements and ensuring that information that is being sought is both able to be provided in a manageable and not overly burdensome way, but also that that information being sought is actually being used with purpose. In a misalignment of these two elements, it can create pretty significant distrust and even animosity in our systems. I think that forward-looking, the coming transparency waves should be focused on ensuring this alignment.
Streeter
Yeah, certainly. We want to avoid animosity. But for a final takeaway, what would you say, Aruna, is a single piece of advice you would like listeners to keep at the forefront of their minds when navigating this multi-layered tax world? I'll ask you first, and I'll get the view from Jose and Manal in a moment. So, Aruna.
Kalyanam
I guess I would say that when it comes to tax transparency, what was once viewed as a burdensome obligation is now being seen as a potential source of opportunity. And businesses need to be dynamic in how they view this opportunity and both be proactive and adaptive in how they want to use their tax function to create value.
Streeter
Jose?
Murillo
I would say, because things are evolving so quickly in this space, you've got to be engaged, be current, and stay out ahead of what's happening.
Streeter
Be on the front foot. Thank you very much. And Manal?
Corwin
I would say that sovereign countries are going to continue, probably more than ever to look for sources of revenue to fund their domestic policy objectives. In so doing, they are going to have a keen interest in protecting the base on which they decide whatever revenue they need. I think transparency will continue to support those efforts, but also has a positive impact on ensuring that the clashes of systems don't end up creating double tax or burdensome enforcement exercises amongst tax administration. It serves a role that should be mutually beneficial for taxpayers and for governments, and it will be critical to continue to support the evolution of it, but also address any of the hazards that were flagged in terms of being unnecessarily burdensome for serving the purpose and having it serve a risk assessment role it was intended to serve.
Streeter
Okay, well, Manal, thank you so much for joining us from Paris at the OECD. And Jose and Aruna, great to have you with us from Washington, DC. Thank you for your time.
Kalyanam
Thanks so much, Susannah.
Corwin
Thank you, Susannah.
Murillo
Thanks very much, Susannah.
Streeter
Before we go, a quick note from the EY team. The views of third parties set out in this podcast are not necessarily the views of the global EY organization or its member firms. Moreover, they should be seen in the context of the time in which they were made. I'm Streeter. I hope you'll join me again for the next edition of the Tax and Law in Focus podcast, EY: Shaping the Future with Confidence.
