Expert Analysis

Jasper Korving and Loes van Hulten of Deloitte provide an overview of the MLI, focusing in particular on the principal purpose test (PPT), an anti-treaty abuse measure in the convention, how the PPT might apply in practice, and its potential impact on companies.

The June 21 decision by the US Supreme Court in South Dakota v Wayfair Inc that overturned, by a 5-4 majority, the previous leading case of Quill Corp v North Dakota has a significant effect on sales taxes within the US. But should businesses outside the US also be very concerned, given that some initial commentary suggested that this would result in a rapid change of the definition of permanent establishment?

The taxpayer challenges arising from the EU’s directive on mandatory disclosures for intermediaries (DAC 6) are seemingly countless, writes Christian Kaeser, global head of taxes at Siemens, and Mark Orlic and Arne Schnitger of PwC.

A recent ruling curbs formalistic proof requirements in EU cross-border pension fund taxation while strengthening the substance over form and ‘equality of arms’ concepts, say João Rodrigues, Liliana Piedade, and Francisco Ludovino Reis of Cuatrecasas

Tax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Nicolas Duboille and Mathis Rossignol of Sumerson analyse the far-reaching implications of a French Supreme Administrative Court decision clarifying the application of Article 123 bis of the General Tax Code

Adrian Rus and Georgiana Bizdrigheanu of EY Romania explain how advance pricing agreements can help taxpayers navigate Romania’s new deductibility limitations and improve predictability and efficiency

Emanuel Băncilă of Băncilă, Diaconu și Asociații SPRL, part of the EY Law global network, outlines practical strategies for Romanian taxpayers facing 'surprise' inspections and procedural limits