Expert Analysis

Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test

KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter

Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion

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

Interview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic

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

Nils Schmid and Isabelle Berking of KPMG Sweden analyse the possibilities for sovereign wealth funds to claim refunds of Swedish withholding tax following a recent proposal referred to the Council on Legislation

Rodrigo Winter Salgado of PwC Chile outlines the country's proposed foreign investment regime, comparing it with past frameworks and highlighting potential tax and legal protections for local and international investors

Alex Lebsanft and Sarah Gard of DLA Piper Australia analyse a recent Full Federal Court decision on the Australian Taxation Office’s application of the country’s anti-avoidance rules to treat capital returns as dividends