6.1 Audit of Multinational Enterprises and Entities with International Operations
| AUTHOR | |
|---|---|
| Marcia Grostein | |
| lectronic document | |
| Spanish and English | |
| CIAT | 2025 |
Contents note:
The CIAT Executive Secretariat invites you to download and read section “6.1 Audit of Multinational Enterprises and Entities with International Operations,” written by Marcia Grostein.
This section provides a practical approach to strengthening the capacity of tax administrations to effectively audit multinational enterprises (MNEs) or international operations. In addition, the publication highlights the importance of training auditors and reinforcing the exchange of information among jurisdictions to ensure proper taxation in the place where value is created.
It details a comprehensive approach that includes:
- – Review of informative returns and transfer pricing studies.
- – Analysis of financial and operational flows through flowcharts.
- – Identification of functions, assets, and risks assumed by local entities.
- – Segmentation of results and interviews with key personnel.
The chapter offers detailed examples of real audits, including cases of restructurings, interposition of entities with low substance, thin capitalization, and interest payments that could conceal dividend distributions.
Given its content, this section will only be available to officials of CIAT member tax administrations, upon request to the following email address: tributacion_internacional@ciat.org.