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.

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.

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

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

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