Substance 2.0: Aligning international tax planning with today's business realities

Is your tax strategy solid enough to withstand today's scrutiny?

Since the first edition of our book appeared in 2009, its subject – economic substance within the context of international tax planning – has only grown in importance. Indeed, across countries and within multinational bodies such as the EU and the OECD, authorities have launched numerous new initiatives focused on so-called "aggressive tax planning", and tax challenges are on the rise.

There are several drivers behind this trend of sharply increased scrutiny.

  • In a challenging economic climate, company shareholders are focused on the top line, and cost containment, including the tax line, is on the radar. However, it is also crystal clear that one should at the same time mitigate the risk of tax adjustments, or worse being negatively exposed for tax planning in the (social) media.
  • Governments, too, are strapped for cash, and are increasingly turning their attention to “soft targets” such as corporate tax revenues.
  • Consumers, the press, and the broader public, empowered by social media, are scrutinising the corporate citizenship, governance and practices – including tax practices – of the companies they buy from.