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.
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.