Expert Analysis

During the past year, there have been a number of international tax developments that are relevant to large multinationals, including some related to the OECD's base erosion and profit shifting (BEPS) project. We will discuss two of the BEPS developments.

International taxation continues to be in a period of extreme change. Recommendations from the OECD's BEPS project are changing laws in countries around the world and multiple jurisdictions are seeking to modernise their tax systems while getting increasingly aggressive in their tax collection tactics against multinationals. As this landscape develops, tax advisory and the individuals who work in it are in massive demand. This is why female advisers need a platform to demonstrate their contribution to the advisory field.

Gabriele Holzinger

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

S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan question the interpretational clarity of the rules and highlight the practical challenges in limiting interest paid to associated enterprises

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