Expert Analysis

In recent years, the idea that offshore tax liabilities can easily be concealed from government revenue collectors has become a moribund concept. Huge data leaks increased international co-operation and developments such as FATCA and the global common reporting standard (CRS) have resulted in a situation where a person’s cross-border tax affairs are no longer fully secret.

International Tax Review hosted its first Women in Tax Forum in New York on March 1. The event kick-started a month of celebrating the brilliant female minds in the sector, their take on some of the hottest tax matters, and insight into their leadership skills and how to be the best.

Since the beginning of the 20th century, banking secrecy has been one of the major marketing points of the famous Swiss banking system, write Jean-Blaise Eckert and Frédéric Neukomm of Lenz & Staehelin. Traditionally, therefore, Switzerland limited any exchange of banking information with foreign states to the minimum.

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

Shaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues

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