Expert Analysis

The term “substance” in the tax practice can have very different meanings. Peter Brülisauer of Deloitte discusses how it is of fundamental importance for the purposes of a substance-based analysis.

Little has changed in Irish domestic tax law to affect M&A transactions in 2016. Nevertheless, international developments, both political and fiscal, have made for a very different landscape, impacting the type of deals being done and indeed the appetite for dealmaking, write Aisling Burke and Caroline Devlin of Arthur Cox.

Steve Edge and James Hume of Slaughter and May face down the biggest issues facing UK taxpayers. Since the article they wrote last year was published, two things have loomed large on the UK M&A horizon.

Dave Yaros, tax principal, Deloitte Tax LLP

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

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