Controversy Management and Transparency Initiatives

A wide range of transparency initiatives have been adopted by tax administrations to obtain 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 such as DAC 6 in the European Union have been implemented over the last two decades. These transparency initiatives are likely to continue, with more being considered in the context of the OECD’s two-pillar solutions and public CbC reports.

How do multinational groups manage the information about their global tax arrangements being shared by tax administrations? What remedies are available to offer protection against the violation of their rights? What are some of the common areas of controversies when dealing with these transparency initiatives? 

Topics Covered

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

Learning Objectives

After this webinar, the participants will be able to: 

  • List the various types of transparency initiatives
  • Apply specific rules related to exchange of information and mandatory disclosure rules to determine the right cause of actions  
  • Assess how multinational groups manage information shared under the transparency initiatives and potential impact on cross-border controversies 
  • Identify the tensions and trade-offs in controversies related to the transparency initiatives, as well as options for resolving these disputes


  • Melissa Kuster, Senior Director, CBRE
  • Konstantin Lozev, European Commision
  • Shee Boon Law, IBFD, the Netherlands
  • Facilitator: Diana Calderon, Senior Associate, IBFD

Field of study


Who should participate

  • In-house tax professionals and advisers looking to understand the impact of transparency initiatives on the international tax arrangements of multinational groups
  • Legal professionals 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
  • Government officials engaging in monitoring and controlling the compliance activities of multinational groups, as well as those involved in auditing their international tax arrangements

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and be familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 3 August 2023

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBA CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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