Expert Analysis

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties

Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead

Dave Yaros, tax principal, Deloitte Tax LLP

With the BEPS rollout continuing apace, transparency continues to be the order of the day across the world, and Latin America is no different.

It would be difficult to imagine a man more ill-suited to high office than Donald Trump, nor a presidency so spectacularly disastrous a mere eight months in. Gung-ho gaffer George W Bush seemed almost statesmanlike in comparison. Even when Trump is calling for peace, love and unity, he gets it wrong.

It's been more than three years since I last had the privilege of writing the editorial in this fine magazine. But after something of a hiatus editing a current affairs magazine, covering such cheery topics as international terror, climate change, North Korean nukes and Donald Trump, I have returned to the world of tax. And what a time it is to be back.

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications

The key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault

The Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan