Cross-border tax compliance in the BEPS 2.0 era
International tax cooperation is no longer an aspiration—it is now a concrete requirement. Automatic exchange of information, more sophisticated transfer pricing rules, and the implementation of BEPS 2.0 Pillar 2 have redefined the operating environment for business groups with a presence in Latin America.
Today, more than ever, companies must adopt a proactive stance in their cross-border tax compliance. This environment becomes even more challenging for those with commercial or corporate ties to the United States, where the IRS, FATCA, and other international regulations impose stricter controls over offshore structures, dividend flows, and corporate reorganizations.
Key elements of the new global tax paradigm:
- Robust transfer pricing documentation, aligned with actual functions, assets, and risks.
- Identification and registration of the ultimate beneficial owner, increasingly required by public registries and banking systems.
- Legitimate tax planning, grounded in economic substance and tax governance—not in legal artifices.
- CbCR reporting and voluntary disclosures as preventive tools to mitigate risks in international audits.
Tax compliance goes beyond simply paying taxes correctly—it entails demonstrating transparency, consistency, and fiscal traceability.
At CENTRAL LAW, we advise our clients across Central America, Panama, and the Dominican Republic on the LEGAL AND TAX COMPLIANCE of their business operations in the region and in cross-border transactions.
We invite you to review together the compliance your business may be needing.
Yolianna Arosemena Benedetti
Partner
Panama
