Controversy Management and Transparency Initiatives
How do multinational groups handle the sharing of information about their global tax arrangements by tax administrations? What solutions exist to safeguard their rights from potential violations? What are some common areas of controversy when dealing with these transparency initiatives?
A wide range of transparency initiatives have been introduced by tax administrations to gather more information about multinational groups’ international tax arrangements following the OECD Harmful Tax Practices project and BEPS Action Plan. Exchange of information in various forms (spontaneous, automatic, and on-request), three-tiered transfer pricing documentation (i.e., CbC reports, Master File, and Local File), exchange of rulings, and mandatory disclosure rules like DAC 6 in the European Union have been implemented over the last two decades. These transparency initiatives are expected to persist, with additional measures being considered in the context of the OECD’s two-pillar solutions and public CbC reports.
Following this webinar, you will be able to:
- Identify the various types of transparency initiatives
- Implement specific rules related to the exchange of information and mandatory disclosure to determine the appropriate course of action
- Evaluate how multinational groups manage information shared under transparency initiatives and the potential impact on cross-border disputes
- Recognize the tensions and trade-offs in controversies related to transparency initiatives, as well as options for resolving these disputes
Block 1: Transparency initiatives in context
- Exchange of information, transfer pricing documentation, exchange of rulings, disclosure rules
- GloBE information return, public CbC reports
Block 2: Managing compliance with transparency initiatives
- Rights and obligations in transparency initiatives
- Managing compliance with various types of transparency initiatives
Block 3: Managing controversy related to transparency initiatives
- Areas of disputes in transparency measures
Melissa Kuster - Senior Director, Global Transfer Pricing and Controversy, CBRE
Konstantin Lozev - Policy Officer, European Commission
Shee Boon Law - Consultant, DLA Piper
Diana Calderon (facilitator) - Senior Associate, IBFD
This webinar will help level up your expertise if you are:
- An in-house tax professionalor adviser looking to understand the impact of transparency initiatives on the international tax arrangements of multinational groups
- A legal professional assessing the compliance risks of transparency initiatives, how to comply with the associated rules and manage the potential controversy risks associated with disclosure and/or non-disclosure
- A government official engaging in monitoring and controlling the compliance activities of multinational groups, as well as those involved in auditing their international tax arrangements
This webinar is for tax knowledge of an intermediate level. You are expected to have at least 3 to 5 years of experience in international tax, and be familiar with key concepts in international tax law.
This is an on-demand tax webinar. Our on-demand webinars are intended for you to self-study only. Unlike live webinars, you will not be able to interact and the instructor will not be able to assist you. Once purchased, you will have access to it for a period of 12 months.
If you have any questions regarding following the webinar, technical requirements, or payments and cancellations, please consult our FAQ.
