Expert Analysis

The work the OECD has done on the BEPS project has shaken the foundations of the tax world. It is almost impossible to recognise the work of all of the people involved.

The phrase ‘Paradise Papers’ evokes images of tropical offshore islands with palm trees and a P.O. address for multinationals and high-net-worth individuals. The list of celebrities involved in one way or another is almost endless. Shakira, Madonna, Keira Knightly, the Queen, Prince Charles, the estate of the late Michael Hutchens, Justin Timberlake, and Amitabh Bachchan. We picture Lewis Hamilton in a private jet.

In 2017, China's State Administration of Taxation (SAT) completed its multi-year TP legislation overhaul by issuing Announcement 6 on special tax adjustments, investigations and MAP. With a distinct anti-avoidance flavour, Announcement 6 preludes the escalation and growing complexity of TP enforcement in China. Cheng Chi, Xiaoyue Wang, Kelly Liao, Mimi Wang and Rafael Miraglia discuss.

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