Expert Analysis

Laws to deal with payments and the deductibility of royalties in Brazil were first introduced in 1958. For the past 50 years, relevant laws have been enacted with the goal of establishing clear rules and limitations. However, in some cases, as explained by Clarissa Giannetti Machado and Juliana Porchat de Assis of Trench Rossi Watanabe, these laws trigger conflicts of interpretation and relevant tax assessments.

Brands are complex intangible assets. As explained by Tim Heberden and Cam Smith of Deloitte, robust valuations and royalty opinions should incorporate analysis of the legal rights underpinning the brand, together with the associated reputational stock that drives purchase behaviour.

The German approach to determining the arm’s-length price for intangibles/intellectual property (IP) is based on the relevant German tax code and related administrative guidance, explain Richard Schmidtke, Bjorn Heidecke and Oskar Glaser of Deloitte. If other methods are used to determine the arm’s-length price for IP, this may result in non-compliance in Germany.

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting say a new regulation underlines the Directorate General of Taxes’ shift towards real-time, data-based compliance enforcement

Magdalena Marciniak and Magdalena Dymkowska of MDDP explain how Poland is sharpening its transfer pricing audits, considering periodic reviews for the largest taxpayers, and increasing the use of tools designed to foster certainty

Fernando Matesanz of Spanish VAT Services examines how the opinion delivered in case C-515/24 addresses whether Spain could limit VAT deduction rights at the moment of its EU accession under the standstill clause