Expert Analysis

This year has been a momentous when considering what the OECD's Centre for Tax Policy and Administration has achieved. Many aspects of the BEPS project have come to fruition even though nobody thought it was possible just a few years ago. But Pascal Saint-Amans says it almost feels like business as usual

The standard for the automatic exchange of tax information (AEOI) is now in operation across the world, and it's Monica Bhatia's team at the OECD Global Forum that has been driving the initiative, as well as growing the number of member countries and driving forward transparency initiatives that have the potential to go beyond taxation.

To say it’s been a busy year for tax disputes in the US would certainly be an understatement. During 2018, the courts have made crucial decisions in cases including Altera, Amazon, Medtronic and Wayfair.

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Patrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines

Nicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications

Inês Dias Cardoso of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the measures and the potential next steps, with a VAT reduction on construction works at the forefront of developments