Expert Analysis

As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency

Senior Deloitte tax practitioners offer guidance for tax leaders on the data, process, technology, and people challenges that arise when organisations go through M&A and explain how pillar two compliance raises the stakes

Marc-Oliver Beste, Florian Escherle, and Maike Moehle of Deloitte discuss how companies can manage pillar two effectively under an optimum operating model and adapt their approaches to data, talent, processes, governance, and technology

Thomas Leventis and Konstantinos Roumpis of Deloitte Greece highlight inconsistencies between Greece’s corporate tax treatment of distributed profits and international practices, and suggest a potential reform to create a clearer and more competitive tax framework

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

Michael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept

Ross Harris of Doane Grant Thornton explains how Canadian transfer pricing amendments increase recharacterisation risk and heighten the need for robust documentation and transaction design

Sal Visca of Vertex explains why tax professionals and authorities must evolve to keep pace with developments such as AI-executed transactions and real-time reporting