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The international tax landscape has undergone radical changes in the last half dozen years. Tax authorities across the globe are implementing strict requirements and enhanced enforcement practices that target perceived tax base erosion and profit shifting. Multinationals everywhere are being forced to increase corporate transparency and disclosure. In short, the rules for and risks of minimizing tax are evolving fast. Perhaps no requirements have undergone such widespread changes as those related to transfer pricing — particularly the OECD’s three-tiered approach to multi-jurisdictional transfer pricing documentation, involving a master file, local file and country-by-country reporting (CbCR). Multinational enterprises of all sizes must understand their related obligations in all relevant jurisdictions to avoid potential double-taxation assessments, penalties and reputational damage.


More than 100 countries are part of the OECD’s Inclusive Framework on Base Erosion and Profit Shifting (BEPS). These jurisdictions are committed to remaking the international tax framework by implementing BEPS rules. Among the key elements of the BEPS program are changes to the permanent establishment (PE) framework to account for the taxation of digital companies, and new, stricter country-by-country reporting (CbCR) obligations related to transfer pricing practices. Unfortunately, individual jurisdictions are implementing new BEPS-related PE and CbCR rules unilaterally and to varying degrees. It’s more important than ever for multinationals to understand these trends so they know the right questions to ask to lower the risk of fines and reputational damage.