Expert Analysis

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

Germany's new government asserts to scrap harmful effects of the transfer of functions legislation, explain Lorenz Bernhardt and Ludger Wellens of PricewaterhouseCoopers

This year's US tax landscape featured substantial international reform proposals, critical litigation about the arm's-length standard and work-product privilege, as well moves to deal with noncompliance by financial institutions, and corporate inversions, report Andrew Kim and Adam Halpern of Fenwick & West

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