Expert Analysis

Tetyana Berezhna

Rustem Ahmetshin

The US, EU member states and other countries have proposed and/or adopted a limitation rule for the deduction of interest by a corporate taxpayer. Will the OECD try to provide worldwide guidance for interest limitation? Is there an expectation for this guidance in the next several years?

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