When the Tax Shelter Becomes the Burning Building

A pharma multinational running operations across Florida, Mexico, Colombia, Spain, and the Dominican Republic had a BEPS-compliant transfer pricing structure — and a profitability problem no one could explain. Pedro San Martín of Asher & Company shows how Oracle EPCM Profitability and Cost Management exposed a USD 57.8M cost gap hiding in plain sight, and why the real battle wasn't with the tax authority. It was with the operating model.