Expert Analysis

In recent years, the number of enquiries received by the Chilean tax authority regarding the impact in Chile from international and cross-border reorganisations has grown exponentially, write Santiago López and Stephanie Chacra of PwC Chile. Indeed, in past international updates we have reported how the Chilean IRS has been formulating uniform criteria for this purpose.

John Gu, Michael Wong and Alan O’Connor of KPMG Advisory take a look back at developments in China’s outbound investments in recent years and look ahead to what this market might hold for investors in the near future.

The public debate over corporate taxation is often emotive, and newspaper readers might presume that corporate tax functions are not doing the right things, writes Jon Dobell, EY global compliance and reporting leader of tax. But for a majority of corporations this perception could not be further from the truth.

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

Fernando Matesanz of Spanish VAT Services analyses a new royal decree, its implementation timetable, and the first points of tension with the EU’s VAT Directive

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