Expert Analysis

Tax information exchange, corporate restructurings and tax havens have been just three issues that have dominated tax coverage in 2009. But as the world enters a new year, deal numbers have begun to rise, companies are making acquisitions and governments are targeting those making money. Jack Grocott and David Stevenson ask some of the world's leading tax personalities what 2009 meant to them and what the future holds for tax in 2010.

Increased foreign investment and regulation are just two of the reasons why the Bric countries have become significant locations for transfer pricing, points-out Shiv Mahalingham of Alvarez & Marsal Taxand UK

The policy of the Mexican tax authorities not to allow the deduction of disbursements in connection with cost sharing agreements looks like a clear case of tax treaty infringement, believe Ricardo Rendon and Oscar Lopez-Velarde of Chevez, Ruiz, Zamarripa y Cia

Sameer Nurmohamed, partner, Deloitte Legal Canada

George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)

Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance