Expert Analysis

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

The choice facing governments is not whether to adopt AI in taxation, but how to do so in a way that upholds the principles of tax fairness, writes Neil Kelley

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

Join ITR for a free webinar on September 30 as insightsoftware, with guest speakers from Alvarez and Marsal Tax, explores how evolving technology is reshaping talent strategies and how organisations can close a skills gap

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Jobst Wilmanns and Anodri Suchdeve of Deloitte Germany introduce this year’s ITR guide presenting transfer pricing insights across several industries, with analysis from Deloitte’s transfer pricing industry experts and factoring in global economic changes

Aditya Hans, Ashish Jain, and Nilesh Chandak of Dhruva Advisors provide an update on India’s implementation of the OECD’s tax reforms after the Union Budget 2024–25 and consider the GloBE rules’ potential impact

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia consider the Directorate General of Taxes’ increasing reliance on technology in transfer pricing evaluation, litigation developments in the area, resolution mechanisms, and mitigation strategies

Teresa Teixeira Mota and André Vilaça Ferreira of VdA discuss the implications of a binding decision regarding the application of double tax treaty provisions to payments made by Portuguese companies to foreign partnerships

Kelvin Yuen and Eddie Ahn of DLA Piper Australia review draft Practical Compliance Guideline 2025/D4, outlining its low-risk zones for cross-border software payments and implications following the recent landmark PepsiCo High Court decision

Edouard Authamayou of Deloitte Luxembourg examines an Administrative Court ruling confirming that tax authorities have full discretion under Section 100a of the General Tax Law to review assessments, with procedural deadlines of critical importance