Expert Analysis

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.

As companies embark on overseas investment and projects under China’s Belt and Road Initiative (BRI), they are increasingly encount­ering tax issues in emerging and developing countries. Michael Wong, Joseph Tam, Alan O’Connor, Karen Lin, and Cloris Li look at key corporate tax issues they may face, and how the SAT is supporting Chinese companies to navigate through these overseas tax challenges.

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