Expert Analysis

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.

Switzerland is known for its high standard of living, political and financial stability, climate for innovation and excellent academic reputation, but is poor in terms of natural resources and has only a small domestic market and a high cost level, note Peter Brülisauer and Manuel Angehrn of Deloitte. Switzerland has to compensate for these market-based disadvantages with a competitive tax system.

All good things are worth waiting for. As such, the long-awaited partial revision of the Swiss VAT Act was finally put into force as of January 1 2018. Laurent Lattmann and Désirée Högger from Tax Partner – Taxand Switzerland expect this will mean closer alignment of the way Swiss and foreign suppliers are treated, and explore how foreign companies must apply the new rules when supplying goods and services to Switzerland.

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