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Direct Tax
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
April 6, 2026
features sponsored features special focus local insights
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Sebastián Arcia Nodari
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Adam Halpern and Larissa Neumann of Fenwick and West examine some of the most important US tax disputes so far this year. -
The Deloitte network of member firms in the Americas deploys the applicable local and regional teams quickly. Deloitte's Americas tax controversy teams consist of more 280 professionals with offices in 130 locations through a network of member firms.
Sponsored Features
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Sponsored by CuatrecasasJosé 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
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Sponsored by DeloitteOlebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa
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Sponsored by DeloitteInterview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands
Special Focus
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Sponsored by EY Central AmericaAntonio 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
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Sponsored by DDTC ConsultingDavid 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
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Sponsored by DeloitteEddie 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
Local Insights
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Sponsored by Tax PartnerMonika 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
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Sponsored by Svalner Atlas AdvisorsPatrik 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
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Sponsored by SumersonNicolas 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
