Expert Analysis

A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements

HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented

In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses

Ronnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work

Sameer Nurmohamed, partner, Deloitte Legal Canada

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

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.

It used to be when one talked about country-by-country reporting (CbCR) and tax transparency, people would look at you like you were some kind of beret-wearing, fist-raising, Trotskyist from Tooting shouting "power to the people!"

Renata Colafêmina and Rafaela Calçada da Cruz of Machado Associados comment on how the consumption tax reform could affect the taxation of carbon assets and environmental projects

India has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime