Expert Analysis

Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout

Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Irsan Pratama and Jeklira Tampubolon of GNV Consulting summarise important updates to the rules governing Indonesia’s Import Facility for Export Purposes, and the exportation of palm oil, palm olein, and cooking oil.

Yves Knel and Anne-Sophie Le Bris of Deloitte Luxembourg continue their analysis of the Multilateral Instrument in relation to real estate by considering methods to eliminate double taxation, focusing on Austria, France, Germany, Poland, and Luxembourg.

Jock McCormack of DLA Piper Australia reports on the forthcoming revision of the country’s thin capitalisation rules, proposals for a new anti-avoidance rule, and the expansion of double tax treaties.