Expert Analysis

Judging by the speeches at the World Economic Forum in Davos, political and business leaders are concerned by the changing dynamics of international tax competition and there can be no doubt that the ‘race to the bottom’ is on.

For months, Congress promoted the tax reform effort as being focused on simplifying the outdated and complex 1986 Tax Code. Tax reform, culminating in H.R. 1, did no such thing, at least where it applies to multinational US corporations. Nowhere is this more apparent than in section 951A, the tax on global intangible low-taxed income, or ‘GILTI’. Erik Christenson, partner at Baker McKenzie, and Monte Silver, senior counsel at Eitan, Mehulal & Sadot explain.

The first component of the UK’s HMRC Making Tax Digital (MTD) project, VAT compliance, goes live on April 1 2019. Corporation tax and income tax will follow in 2020 or later, writes Richard Asquith, vice president of global indirect tax at Avalara.

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Interview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic

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

The ruling clarifies that Spain cannot restrict VAT exemptions for general services directly necessary to independent groups’ exempt activities, says Fernando Matesanz of Spanish VAT Services

Gabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps

Nils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation