Expert Analysis

Advisers from Deloitte LATCO (Latin America Countries Organisation – a cluster that includes all countries in the region except Brazil, Chile and Mexico) contribute to a regional roundup of the major transfer pricing implications of reforms initiated to counter base erosion and profit shifting (BEPS).

Dan Roman and Aron Joy of KPMG look back on Anson, tracking the background to the case before focusing on the types of structure that could be affected by the decision and how this impact may manifest itself in practice.

Rafael Sayagues, Isabel Chiri and Alexandre Barbellion of EY look at the role of Central American countries Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Nicaragua and Panama in the global tax playground and whether a cascading ‘tax bullying’ effect can be seen when global trends are established

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Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

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

Ahdianto Ah and Aditya Nugroho of GNV Consulting explain recent Indonesian tax reforms affecting business restructurings, treaty access, and enforcement

Ahdianto Ah and Aditya Nugroho of GNV Consulting summarise an extension of the government-borne incentive, new risk-based taxpayer compliance supervision rules, and revised mutual agreement procedure guidelines

Rabie Morsy and Ahmed Khalifa of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt analyse the amendments and guidance, focusing on construction, commodities, exemptions, and practical compliance implications for businesses