Expert Analysis

The OECD’s BEPS initiative has sparked a global focus on MNEs and their transfer pricing. In recent years, writes Tony Gorgas of KPMG Australia, there has been a profound change in the ASPAC region as governments and tax administrations seek to ensure multinationals pay their fair share of tax in line with economic and value creation.

The Pakatan Harapan coalition formed a new government in May 2018 after defeating the Barisan Nasional coalition that had ruled the country for more than six decades, write Bob Kee and Mei Seen Chang of KPMG. This major shift in the political landscape of Malaysia is affecting the economic and business environment.

Singapore has been increasing its focus on transfer pricing, explain Geoffrey K Soh, Felicia Chia and Jingyi Lee of KPMG, with yearly revisions of the TP guidelines as well as the adoption of country-by-country reporting requirements. Recently, there has been a greater-than-ever push to ensure that taxpayers’ profitability is consistent with the economic activities conducted and value generated.

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

Julien Lamotte of Deloitte Luxembourg explains how the new regime positions the country as a leading destination for alternative investment funds while providing tax-efficient treatment

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente explain how Italy classifies payments for software distribution and the potential consequences in the event of a tax audit

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