Expert Analysis

The Tokyo District Court recently issued two judgments regarding transfer pricing (TP) cases, both in relation to the treatment of intangibles. These decisions provide insights into how the Japanese tax authorities will evaluate intangibles when dealing with TP issues in audits going forward, explain Yutaka Kitamura and Jun Sawada of Deloitte.

There is a lot of discussion about the future of the financial services sector, write Ralf Heussner and Enrique Marchesi-Herce of Deloitte. New technologies and automation, a changing regulatory landscape, and the entry of new market players are reshaping the industry. On top of this, the industry is undergoing further consolidation while having to respond to shifting customer demands and new distribution models.

We have seen a strong start to 2018 in terms of M&A activity, write Jon Vine and Greg Smith of Deloitte. Mergers and acquisitions invariably involve a range of complex tax issues. While these continue to include matters such as acquisition structuring, financing and structurally integrating the acquired business, the complexity and range of transfer pricing (TP) issues which arise in the M&A context should not be underestimated.

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Interview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic

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

The ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services

Gabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps

Nils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation