Much time and attention has been devoted to planning for a post-BEPS world, from analysing systems that may need to be adopted to looking at how taxpayer-tax authority relationships are likely to change. But less has been said about the impact of BEPS deliverables on commercial contract documentation and the extent to which such contracts will be scrutinised. Jen Winterhalder, a solicitor in PwC Legal and Latika Sharma, a partner and head of PwC Legal’s intellectual property and commercial contracts team, focus on the importance of matching contract terms to commercial substance, both now and for the future.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London