Expert Analysis

The arm’s-length principle establishes that the conditions agreed between two related enterprises in their commercial or financial transactions cannot be different to those made between independent parties, writes Alejandro Paredes Maldonado of Deloitte Chile. If they differ, the profits of those enterprises may change and will be taxed accordingly.

Global transparency is one of the hottest topics of discussion in the policy agendas of governments around the world. Developed and developing countries alike are being urged to establish a more robust legal framework in an effort to meet international standards on tax transparency, write Rafael Sayagués, Alexandre Barbellion and Isabel Chiri of EY Central America.

The recent conclusion of the impeachment trial of Dilma Rousseff brings a new wave of optimism to Brazil, but there are huge challenges that the new president will need to tackle fiercely and urgently, say Simone Musa and Adriana Stamato of Trench, Rossi e Watanabe Advogados.

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Raghav Rajeev and Nimrah Ali of Lakshmikumaran & Sridharan analyse the approaches taken by taxpayers and Indian judicial bodies on contested tax payments under the country’s goods and services tax law

Bernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address

Tiago Marreiros Moreira, Rita Simão Luís, and Nadine Gomes of VdA analyse how recent EU VAT and energy tax developments shape electric mobility, highlighting opportunities from CJEU rulings and challenges of multi-layered tax frameworks