Expert Analysis

The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

The tax regimes governing the gig economy, combined with the rules on self-employed individuals, have led to the success of companies such as Uber and Deliveroo. However, the Taylor Review on modern working practices has suggested radical changes that could change it all and stop other sectors adopting similar practices. Anjana Haines talks to the report’s author, Matthew Taylor, to discuss his recommendations and what they could mean for the future of the gig economy.

All companies operating in the UK and abroad could be liable to criminal penalties if they or their associates are found to be facilitating tax evasion. Dominic Stuttaford, head of tax at Norton Rose Fulbright for the EMEA region, highlights the impact of the new Criminal Finance Act and what companies need to being doing now to ensure compliance.

Lisa Zajko, indirect tax partner, Deloitte Canada

João Riscado Rapoula and Hugo Leonardo of VdA analyse the new Construir Portugal scheme, outlining how targeted tax incentives are reshaping the country’s landscape for affordable housing investment and residential real estate

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

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

André Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny

Samuel Fernandes de Almeida and Ana Rita Carvalho of MFA Legal & Tech explain how a Portuguese binding ruling fuels the emerging dispute with Spain over non-habitual tax residents

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse a recent ruling of the Italian Supreme Court that clarifies the conditions for the deductibility of costs related to intercompany services