• Tax disclosure (EU-AAC 6) • Exchange of tax rulings • Insurance of tax risks, warranties and indemnities • Tax disputes and litigation • Role of tax administration - difference in outlook developing economics vs. emerging economies • MLI interplay with domestic laws and BEPS • MAP, PAA • Key features of OECD International (Tax) Compliance Assurance Programme (ICAP) • Increasing enforcement actions and proposed multi-national co-operation among tax authorities • Aggressive tax planning disclosure • OECD base erosion rules • Implementation of first and second ATAD directives • Is arbitration future of contentious practice - scope of arbitration under MLI • EU tax competition in post BEPS / ATAD world • New mandatory automatic exchange of information for reportable cross border arrangements • Facing Chinese and other Far East source state taxation