Expert Analysis

In light of the US Tax Court’s decision in Amazon v. Commissioner of Internal Revenue, many important predictions have been made about the impact this case will have on future transfer pricing litigation. However, it is important to look at the valuable lessons that should be learned by practitioners, corporations, attorneys, and tax authorities when documenting intercompany transactions, specifically intangibles. John Wiora, director of operations at ktMINE, investigates.

Financial institutions are busy filing their first reports to tax authorities to comply with the common reporting standard (CRS), but loopholes in the global measure mean some taxpayers can remain undetected. Amelia Schwanke highlights the gaps appearing and the jurisdictions enabling them.

Country-by-country reporting (CbCR) deadlines are approaching and MNEs are carefully preparing the information and diligence behind the numbers. CbCR brings us to the next phase and Keith Brockman asks how reputational risk will be questioned by the public (if disclosed) and defended or ignored by MNEs and tax administrations.

Governments’ unprecedented access to transactional data is creating new indirect tax challenges for multinationals. Alex Baulf of Avalara summarises key regional developments ahead of a webinar sharing his practice-based insights

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

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

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

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