Expert Analysis

Rodrigo Winter Salgado and Raul Fuentes Ugalde of PwC provide an update on imminent changes and the status of tax in the digital economy (DE).

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.

The OECD BEPS project has quickly moved to the implementation phase, leaving an essentially changed landscape in its wake, write Deloitte practitioners from the Latin America Countries Organisation. This new environment requires businesses to reconsider their operational, financing and holding structures, identify communications strategies and assess their tax strategy, all with the aim of developing a maintainable tax framework.

A recent ruling curbs formalistic proof requirements in EU cross-border pension fund taxation while strengthening the substance over form and ‘equality of arms’ concepts, say João Rodrigues, Liliana Piedade, and Francisco Ludovino Reis of Cuatrecasas

Tax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk

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

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

Nicolas Duboille and Mathis Rossignol of Sumerson analyse the far-reaching implications of a French Supreme Administrative Court decision clarifying the application of Article 123 bis of the General Tax Code

Adrian Rus and Georgiana Bizdrigheanu of EY Romania explain how advance pricing agreements can help taxpayers navigate Romania’s new deductibility limitations and improve predictability and efficiency

Emanuel Băncilă of Băncilă, Diaconu și Asociații SPRL, part of the EY Law global network, outlines practical strategies for Romanian taxpayers facing 'surprise' inspections and procedural limits