Expert Analysis

Following approval by all members of the BEPS inclusive framework, the OECD has publicly released the substance and process for the peer review of BEPS Action 14.

The OECD BEPS Actions will result in a higher effective tax rate (ETR) and cash tax liability for most multinationals, whereas investors will continue to strive for lower ETRs and cash tax liabilities in the companies they consider for investment. Keith Brockman looks at where the balance should be in this equation, and who should be the master negotiator.

Brazil’s retail sector is shrinking, but governments want more revenue, so where does that leave businesses? The tax chief at international fashion retail company C&A talks to Amelia Schwanke about the changes taking place in the notoriously complicated tax jurisdiction.

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead

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

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