One of the inevitable consequences of the major changes to international corporate taxation – from the G20/OECD-led Base Erosion & Profit Shifting (BEPS) project and unilateral changes – is uncertainty. Every time tax directors are surveyed on the challenges of their role, uncertainty is always listed as the biggest issue faced.

The G20 commissioned a study from the International Monetary Fund and the OECD on the causes of tax uncertainty and possible solutions. Their report was delivered in March 2017 and noted that tax uncertainty was the single biggest barrier to foreign direct investment and growth. At the same time, tax administrations reported that reducing tax uncertainty was a key priority.