International taxation will tighten its controls in 2026: strategic keys for managers and companies

The adoption of OECD Pillar Two and increased global transparency require companies to review their structures and transfer prices to avoid penalties.

La Chamber of Commerce, Industry and Services of Madrid It hosted a technical conference on international taxation to analyze how companies should adapt their tax and other strategies. transfer pricing in the face of greater global regulatory control to prevent double taxation.

During the institutional opening, Saul JimenezThe technical advisor for international trade at the chamber of commerce welcomed the attendees, highlighting the focus of the meeting: «We are in the Madrid Chamber of CommerceWe've just been talking about international taxation and transfer pricing. We tried to make it a practical session with interesting cases so that the audience could understand how it works in practice..

The New Paradigm of International Taxation

The global tax landscape is undergoing an unprecedented transformation toward control and transparency. More than 135 jurisdictions are unifying their regulations, driven by initiatives such as the Pillar Two from the OECDwhich sets a global minimum tax rate of 15% for certain multinational corporations. This new framework has generated more than €135.000 billion in tax revenue worldwide.

Global Indicator	Figure / Data
Jurisdictions aligning tax regulations	More than 135 jurisdictions
Minimum tax rate (Pillar Two) OECD)	15%
Tax revenues revealed worldwide	More than 135.000 million euros

In this scenario of regulatory change, David Sardá SespluguesPartner in the Tax Department of BDO Lawyers and Tax AdvisorsHe emphasized the enormous operational impact: "We are in a situation where international taxation is tightening its rules, reviewing controls in all jurisdictions, and is also becoming more international.".

Likewise, David Sardá Sesplugues He warned that the correct application of concepts such as tax residency and transfer pricing poses a cross-cutting challenge: "not only for large companies, but also for startups"emphasizing that "Anticipatory decision-making in the face of all these new developments and synergies that are occurring between the different jurisdictions is key to being able to develop the company's activity.".

Analysis of Corporate Structure: Substance-Based Approach

In the same line, Veronica Targa, Manager of the Tax Department of BDO Lawyers and Tax Advisors, delved into the need to apply an approach substance-based (based on economic substance). What was once a standard corporate structure can now lead to tax adjustments, audits, or risks of double taxation if it lacks a solid economic justification behind the operations.

The main practical points addressed for companies include reviewing:

• The use and feasibility of international holdings and foreign entities.
• The operational and fiscal distinction between branches and subsidiaries.
• The management of international flows of dividends, interest and royalties.
• The challenges arising from the new international tax transparency and anti-abuse clauses.

Transfer Pricing and the Role of the Chief Financial Officer

The scope of the transfer pricing He is one of those most affected by the scrutiny. Gabriel Yakimovsky, Director of the Fiscal Department of BDO Lawyers and Tax Advisors, 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 the CFO, the challenge lies in identifying when the pricing policy has ceased to reflect the reality of the business, adapting the changes in a coherent, traceable and defensible manner before the Administration, always analyzing the opportunities and risks when modifying the methodology.

Institutional Agenda and Strategic Partners

The event was supported by key strategic partners for corporate internationalization, such as Kuehne+Nagel, the Enterprise Europe Network and Region of Madrid.

Opening hours	Session Description	Speakers
09: 30 pm	Institutional opening and presentation	Saul Jimenez
09: 40 pm	Block I | International Taxation: The New Global Landscape	David Sardá Sesplugues y Veronica Targa
10: 40 pm	Block II | Transfer Pricing: Policy Changes	Gabriel Yakimovsky

Key points and frequently asked questions about International Taxation 2026

What is Pillar Two of the OECD?

It is a global regulation aligned by more than 135 jurisdictions that sets a minimum rate of 15% for certain companies, seeking to prevent tax avoidance and increase international transparency.

Why do transfer pricing policies need to be updated?
Because the tax authorities now use more sophisticated data analysis and exert greater control. Policy must cease to be static and become traceable, defensible, and consistent with current economic realities.

What does the "substance-based" approach imply for corporate structures?
This means that all structures, such as holding companies or dividend flows, must have a sound economic and operational justification. Otherwise, companies risk inspections, severe tax adjustments, or double taxation.