Expert Analysis

Lothar Siemers and Martin Liebernickel of PwC explain the background to, and fallout from, a recent judgment stating that inheritance tax relief on the transfer of business property is unconstitutional.

Claus Jochimsen of PwC gives an overview of the tax law changes introduced under the label of the ZollkodexAnpG.

Susann van der Ham and Guido Schepers of PwC discuss the recently approved ordinance on the application of the arm’s-length principle to permanent establishments (PEs), addressing the impact of the introduced section 39 of the ordinance on the attribution of profits to dependent agent PEs in Germany to analyse whether the ordinance approval signals the start of an era of dependent agent PE discussions.

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

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

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks

The regime has modernised the taxation of employee equity, but several lingering shortcomings leave room for enhancement, say João Riscado Rapoula, Miguel Gonzalez Amado, and Ana Francisca Ribeiro of VdA

Sandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions