Expert Analysis

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

MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

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

Miguel Gonzalez Amado and Mariana Pinto Monteiro of Vieira de Almeida & Associados consider the tax personality of Portuguese branches for stamp tax purposes and a recent ruling’s potential impact on cross-border credit operations

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