Expert Analysis

In 2017, the China customs authorities took major steps to revamp their existing national structures, with consequences for audit processes and enforcement approaches. In this chapter, Eric Zhou, Rachel Tao, Cheng Dong, and Helen Han explore the impact of these reforms.

John Gu, Yvette Chan, Chris Mak, and Sam Fan explore the M&A tax challenges arising in hot sectors like TMT and healthcare, and for take-private transactions, establishing how investors can best get prepared. They note how, given the pace of developments and tax uncertainties, there is a need for the China tax authorities to provide greater clarity. More than ever, appropriate tax planning is crucial for M&A transactions.

The disparity between China’s rapidly developing and evolving digital economy and its largely traditional economy-based tax administration system is growing, and is creating challenges for both the tax authorities and taxpayers. Sunny Leung, Benjamin Lu, Jessie Zhang, and Grace Luo explore the issues.

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