Expert Analysis

Gilberto de Castro Moreira Jr

Mariano Ballone

Welcome to the 2018 edition of the Tax Controversy Leaders guide from the International Tax Review. This is the eighth annual publication of the list of the world's leading tax controversy practitioners and marks a significant step in its evolution. Beginning this year, we are looking to grow the guide in both scope and scale. It will cover more jurisdictions, reach out to more individuals and recognise more practitioners than ever before – from rising stars just making a name for themselves to market leaders with decades of experience behind them

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

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

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

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

Sofia Araújo Alves of Morais Leitão, Galvão Teles, Soares da Silva & Associados explains the Carbon Border Adjustment Mechanism’s transition to its definitive phase, highlighting new compliance requirements, thresholds, and regulatory simplifications

Monika Marta Dziedzic and Paweł Wyciślik of MDDP outline how 2026 marks a shift towards digital tax compliance in Poland, with mandatory e-invoicing, enhanced reporting obligations, and targeted reforms shaping the year ahead

Fernando Matesanz of Spanish VAT Services welcomes a CJEU ruling clarifying how tax authorities should verify cross-border movement of goods to apply the VAT exemption