Expert Analysis

Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage

Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities

The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment

Interview with Chris Atkinson, partner, tax and legal, Deloitte Australia

Interview with Eric Lesprit, partner, transfer pricing, Deloitte Société d’Avocats, France

Haryati Hamzah, Jan De Clercq, and Stephen Losavio of Deloitte share lessons on how tax leaders can get more of what they need in ERP system upgrades to help keep pace with tax authorities’ growing demands

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Tiago Marreiros Moreira and Francisca de Landerset of VdA explain the challenges of attributing profits to a management permanent establishment in Portugal, highlighting OECD guidance, board member activities, and documentation requirements for compliance

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici examine key issues in Italy’s transposition of DAC8 and the challenges posed by technological transformation in the digital economy

Gabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform test phase, pending regulations, and key concerns for businesses