In a world shifting towards full transparency on tax matters, a key challenge, among others, for the tax authorities will be to determine how best to deploy their available audit resources. Along with the benefits of obtaining ‘tax information’ on an almost ‘real time’ basis, there are quite some controversial topics for the tax authorities to deal with, such as:
- Can I apply BEPS reports on all open tax years, with the risk of applying BEPS norms with a retrospective impact?
- How to rank these information flows coming my way in terms of collecting ‘objective evidence’ on facts on which taxation takes place? AND
- How do I maintain a certain level of international tax and BEPS expertise to facilitate a normalized communication with taxpayers on these complex matters?
Tax authorities are recommended to:
- Understand a multinationals’ business model;
- Assess a taxpayer’s tax positions/issues in selecting ‘audit cases’;
- Rank the ‘evidence based facts’ to facilitate communication with taxpayers based on arguments;
- Facilitate the right of multinationals against unjust taxation, where the taxpayer’s conduct has demonstrated ‘good faith’ compliance with the tax rules and regulations.