Expert Analysis

Around 20 years ago the Brazilian Government, in order to deter tax evasion in the country, introduced rules aimed at avoiding the undue transfer of profits through transactions conducted between multinational companies and their parents or associates abroad, writes Carlos Ayub of Deloitte Brazil. Since then, all movements of goods, services, and rights between entities in the same group have been subject to transfer pricing rules.

In the hype of the BEPS Project, Mexico has been one of the most active countries in applying the concepts of substance, transparency and consistency, write Simón Somohano and David Cárdenas of Deloitte.

The European Commission’s long-awaited state aid decision on tax rulings issued by Ireland to US-multinational Apple has created a political typhoon. It has invited an unprecedented response from all involved parties, with some hailing the decision as a victory and others criticising the tax charge as excessive or even unwarranted. Anjana Haines and Amelia Schwanke report on the recent developments.

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