The issues that arise from the BEPS actions points are, at first glance, technical tax questions. Are these the domain of the corporate tax team? Looking a little more closely, however, they become a question of fact – detailed fact. These questions require data and an understanding of the people aspects, as much as the technical aspects.
Detailed information about people and their activities will most likely need to come from the HR and Global Mobility teams. This involves knowing who is working where and what is the scope of their duties, in practice as well as on paper.