Expert Analysis

With a general election looming, the New Zealand government has unveiled a raft of measures intended to counter base erosion and profit shifting (BEPS) that, in some respects, go further than any of the OECD’s BEPS recommendations. Brendan Brown and Tim Stewart of Russell McVeagh in New Zealand explain the recent announcements, which include measures to address permanent establishment avoidance, significant changes to the transfer pricing and thin capitalisation rules, measures to address hybrid mismatch arrangements, and various measures (going beyond the OECD’s BEPS recommendations) to increase Inland Revenue’s enforcement powers.

Tax risk is a modern ‘term of art’ perception; this risk can be viewed as a pendulum. Keith Brockman looks at the advantages of corporate collaboration and threats of uncertainty and public distrust.

Neeru Ahuja

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

Alex Lebsanft and Sarah Gard of DLA Piper Australia analyse a recent Full Federal Court decision on the Australian Taxation Office’s application of the country’s anti-avoidance rules to treat capital returns as dividends

Jian-Cheng Ku and Taco Pennings of DLA Piper Netherlands discuss a recent ruling by the Dutch Supreme Court regarding the calculation of corporate income tax interest

Tiago Marreiros Moreira and Rita Pereira de Abreu of VdA explain how the ruling eases administrative hurdles for foreign pension funds claiming Portuguese withholding tax exemptions