Expert Analysis

The OECD has continued to evaluate and work on refining its transfer pricing guidelines regarding several BEPS initiatives, write David Jarczyk and John Wiora of ktMINE.

With the CCCTB back on the EU agenda, Richard Murphy, professor of practice in international political economy at City, University of London, argues it does not represent true consolidation and could fail in its objectives.

Austrian Federal Minister of Finance Hans Jörg Schelling has not held back on his views of how to tax multinational corporations so they pay their fair share. He talks to Anjana Haines about what he has planned over the coming year.

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

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

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