Expert Analysis

The European General Court (EGC) has ruled against the European Commission in the Apple case, meaning the US company does not have to repay €13 billion ($14.8 billion) in state aid benefits it received in Ireland.

Businesses are finding it difficult to deal with transfer pricing (TP) data and how to apply an arm’s-length analysis in a global economy that looked completely different just six months ago.

As countries provide incentives to attract foreign investment, the OECD may have to readdress the BEPS framework in the post-COVID future.

Join ITR and Thomson Reuters on July 16 as a three-part webinar series concludes with real-world insights into how businesses are managing the e-invoicing transition and the strategies enabling global compliance

Johan Van der Paal and Bram Fouache of Deloitte Belgium explain how the EU’s VAT in the Digital Age Directive is reshaping VAT compliance across Europe, and how businesses can prepare for digital reporting and e-invoicing reforms

Sudin Sabnis and Siddhesh Khandalkar of Lakshmikumaran and Sridharan explore how context shapes the interpretation of undefined terms in tax treaties, balancing treaty text, domestic law, and diplomatic intent

Vanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile

Senior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica

Senior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation

Karanjot Singh Khurana, Prachi Bharadwaj, and Vrinda Agrawal of Lakshmikumaran & Sridharan analyse the tax deduction challenges arising when employee stock option plans are implemented via trusts

Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici analyse an Italian Supreme Court decision that addresses the tax treaty concept of a fixed base, highlighting concerns over legal certainty and double taxation

Rafael Calvo and Adrián Arroyo of Garrigues Madrid discuss a National Court judgment clarifying that interest on equity (JSCP) received from Brazilian entities qualifies for an exemption under the Spain–Brazil double tax treaty