Expert Analysis

Chinese tax authorities are increasing their scrutiny of high and new technology enterprises, which stresses the importance of strong documentation, says Abe Zhao of FenXun Partners

Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems

The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world

Amit Maheshwari and Manish Garg of AKM Global provide a guide to the UAE’s nascent regulatory framework for transfer pricing and offer strategies to ensure compliance and the maintenance of proper documentation

D’Arcy Schieman, partner, indirect tax, Deloitte Canada

Walter Di Rosa, lead litigation team partner, Deloitte DCM – Italy

Shaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space

Dennitsa Dimitrova of Kambourov & Partners Tax Consulting highlights a significant tax risk in M&A transactions involving telecommunications operators and suggests what steps should be taken during the due diligence process

Vrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how an Italian Supreme Court ruling has clarified the transfer pricing treatment of transactions between affiliated Italian companies

Monika Marta Dziedzic and Paweł Wyciślik of MDDP discuss several tax reforms set for 2025 in Poland, including implementation of the GloBE rules, real estate tax changes, and mandatory corporate income tax reporting

Aditya Wicaksono and Dwipa Abimanyu Dewantara of GNV Consulting explain how Indonesia hopes to benefit from new regulations concerning proof of origin of imported goods, excise exemptions, and four-wheeled battery-based electric vehicles