Expert Analysis

Increasing cross-border business and investment has made the holding of assets overseas through offshore accounts increasingly common. This has become a new tax battleground for businesses and governments. Charles Kinsley, Henry Wong, and Eva Chow look at the latest developments regarding these efforts in China, Hong Kong and Taiwan.

In 2017, the Taiwan government proposed imposing VAT on foreign enterprises providing e-commerce services to Taiwan individuals, expanding the Taiwan corporate income tax (CIT) nexus rule, and making personal income tax changes. It is also looking at abolishing and replacing the corporate-shareholder imputation tax system. Stephen Hsu, Hazel Chen, Ellen Ting and Betty Lee elaborate.

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.

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