Expert Analysis

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.

In 2017, we saw significant new China individual income tax (IIT) enforcement trends in relation to outbound and inbound expat tax monitoring and audit, as well as equity incentive schemes. Michelle Zhou, Jason Jiang, Sheila Zhang, Angie Ho, and Murray Sarelius highlight areas to watch for in the future.

Darren Bowdern, Matthew Fenwick, and Malcolm Prebble explore the various initiatives that the Hong Kong government has introduced to boost Hong Kong’s position as a regional management hub in Asia. While Hong Kong is making positive changes to attract more funds to domicile in Hong Kong, more tax certainty is needed to convince fund managers to move.

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

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici analyse the recent amendments to the Italian tax regime governing intercompany dividends and assess their likely impact on international investment structures

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