Expert Analysis

Microsoft has long managed its tax affairs through a network of structures spanning the world. Josh White analyses how US tax reform might hit these arrangements, and the jurisdictions they rely on, such as Ireland, Puerto Rico and Singapore.

Are new laws incapable of being subject to statutory construction to depict their meaning? Or are such laws so poorly drafted that companies must glean their intended meaning, outside the parameters of the legislated verbiage, from conference reports, statements of intent by tax authorities at international conferences and referencing documents?

Jorge San Martín and Sebastian Ayza of SMPS Legal explore the complexities of the tax-related aspects of mergers and related transactions involving foreign legal entities in Mexico.

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

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

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