International Taxation in 2026: A Constantly Evolving Challenge

 

International taxation has entered a phase of greater control and transparency. This conference will address how regulatory changes impact internationalized companies, offering practical insights for Spanish executives in the face of increasing global scrutiny in 2026.

 

The New Paradigm of International Taxation in 2026

 

The global tax landscape is undergoing an unprecedented transformation, marked by closer coordination between tax administrations. More than 135 jurisdicciones They are unifying their regulations, driven by key initiatives such as the Pilar Dos de la OCDE, which establishes a global minimum rate of 15% for certain companies.

 

This trend, coupled with the automatic exchange of information, has allowed more to surface 135.000 millones de euros in global tax revenues, creating an environment of greater scrutiny regarding international structures, intragroup transactions, and companies' tax policies. What was once common practice now requires robust economic justification to avoid tax adjustments, audits, or the risk of double taxation.

 

In this context, David Sardá Sesplugues, partner in the Tax Department of BDO Abogados y Asesores Tributarios, together with Verónica TargaThe manager of the same department will address the importance of understanding this new framework. During their presentation, they will discuss current trends in international taxation, with a "substance-based" approach, and the evolution of double taxation treaties.CDI), the MLI, Pilar Dos and anti-abuse clauses as central elements. Crucial practical aspects for the company will be covered, such as:

 

• The use of international holdings.
• The distinction between branches and subsidiaries.
• The management of dividend, interest and royalty flows.
• The challenges of international tax transparency.

 

Transfer Pricing: Strategic Adaptation for the CFO

 

The area of ​​transfer pricing is also directly affected by this tightening of tax controls. Gabriel Yakimovsky, director of the Fiscal Department of BDO Abogados y Asesores TributariosHe warned that "in a context of greater fiscal control and more sophisticated data analysis, transfer pricing policy can no longer be a static document."

 

For CFO (Chief Financial Officer), the main challenge lies in identifying when the current policy has ceased to reflect the reality of the business and how to implement changes in a coherent, traceable and defensible manner before the Administración Tributaria.

 

Practical Workshop: Anticipating Regulatory Changes

 

The event is aimed at empresas internacionalizadas, pymes exportadoras and professionals in the financial, tax, legal and foreign trade fields who operate or plan to operate in mercados internacionales.

 

Key Benefits for Managers and Professionals

 

Attendees will have the opportunity to:

• Understand how the new tax changes affect your international structure.
• Understanding the current risks in transfer pricing and intragroup operations.
• Identify when it is appropriate to rethink holdings, subsidiaries or international flows.
• Anticipate possible tax contingencies and criteria for greater scrutiny.
• Access a practical and up-to-date view of the international taxation in 2026.

 

Agenda and Expert Speakers

 

The day will take place on 27 de mayo in the Calle Huertas n 13, 28012 Madridwith a structured program to maximize practical value for attendees:

 

Opening hours	Description	Speakers
09: 15 pm	Reception and registration of attendees
09: 30 pm	Institutional opening and presentation of the day	D. Saúl Jiménez (Cámara de Comercio, Industria y Servicios de Madrid)
09: 40 pm	Block I | International Taxation: the new global playing field (Trends, Double Taxation Treaties, Pillar Two, holdings, subsidiaries, flows)	D. David Sardá Sesplugues y Dña. Verónica Targa (BDO Abogados y Asesores Tributarios)
10: 40 pm	Block II | Transfer Pricing: Changes in Pricing Policy (When to Reassess, Opportunities and Risks)	D. Gabriel Yakimovsky (BDO Abogados y Asesores Tributarios)
11: 30 pm	Frequently asked
12: 00 pm	Coffee & networking

 

Key points and frequently asked questions about International Taxation in 2026

 

How does the OECD's Pillar Two affect internationalized Spanish companies?

El Pilar Dos de la OCDE establishes a global minimum rate of 15% for multinationals with revenues exceeding 750 millones de eurosFor Spanish companies, this implies a thorough review of their tax structures and the need to ensure that their foreign subsidiaries or parent companies comply with this threshold, avoiding adjustments and possible penalties for insufficient taxation in low-tax jurisdictions.

 

What tax risks do exporting SMEs face with their current structures?

pymes exportadorasalthough they are often not directly subject to Pilar DosCompanies are affected by the widespread increase in international tax scrutiny. Common structures such as holding companies or subsidiaries that lack a solid economic justification ("substance-based") may be questioned, leading to risks of double taxation, audits, or adjustments to their intragroup transactions, especially regarding transfer pricing.

 

What should Spanish CFOs consider in their transfer pricing policy?

The CFOs Spanish companies must understand that transfer pricing policies can no longer be static. It is critical to continuously monitor business realities and adapt pricing methodologies dynamically, consistently, and with defensible documentation. The key is to anticipate regulatory changes and ensure that the pricing policy reflects the functions, assets, and risks assumed in each intragroup transaction to avoid disputes with tax authorities.

 

Registration: