Expert Analysis

US tax reform won’t happen – or will it? Many are awaiting the enactment of the US tax reform proposals, which will have a worldwide impact, and the so-called ‘Big Six’ policymakers have had the biggest influence on the plans so far and will continue to steer the debate as it makes its way through Congress.

New data and technology-driven, risk-oriented, tax administration and enforcement approaches by the Chinese tax authorities are compelling taxpayers to up their game. Taxpayers are developing enhanced internal tax risk controls and IT, and engaging with the tax authorities in a collaborative manner. Tracy Zhang, Wei Fang, Anthony Chau, Lilly Li, discuss the latest trends and changes.

Ayesha Lau, Darren Bowdern, Michael Olesnicky, John Timpany and Curtis Ng discuss Hong Kong’s BEPS-related changes after the territory issued a consultation paper to codify and strengthen TP regulations, as well as joining the Multilateral Instrument (MLI). The Hong Kong government is also increasingly using tax policy to encourage economic development.

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Kathya Capote Peimbert of Vertex examines how continuous transaction controls expose under‑addressed intercompany transaction risks, and outlines the approach multinationals should take to ensure consistent VAT treatment and improve audit defensibility

Aditya Wicaksono and Reza Farhan of GNV Consulting outline new Indonesian tax provisions concerning penalty waivers, filing extensions, and compliance protections introduced under recent regulations supporting the roll-out of the Coretax system

Diana Lupu and Ana-Maria Nițu of EY Romania explain when entities subject to the global minimum tax can transition to IFRS, the key benefits and challenges, and the implications for financial reporting and compliance