Expert Analysis

New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer

AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems

Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria

Yong Chan Lee and Eun Jin Choi of Deloitte Korea provide an update on the application of the OECD’s two-pillar solution and explain how Korean businesses can prepare for amount B’s introduction

Sanjay Kumar and Suchint Majmudar of Deloitte India provide a guide to the BEPS package and explain why streamlining the calculation of amounts A and B is integral to its successful implementation

ITR considers how insightsoftware’s Certent Disclosure Management platform addresses the various issues surrounding disclosure reporting requirements and finds it could be a powerful ally for under-pressure tax professionals

Vanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile

Senior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica

Senior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation

Francisco Cabral Matos and Francisca de Landerset of VdA examine Portugal’s tax neutrality regime for mergers and demergers, highlighting how rigid interpretations by the tax authority are undermining its practical application

Paulo Victor Vieira da Rocha and Marina Fernandes of VRMA Advogados discuss a landmark trial at Brazil’s Federal Supreme Court on the taxation of profits earned by foreign subsidiaries and affiliated companies

Karanjot Singh Khurana, Prachi Bharadwaj, and Vrinda Agrawal of Lakshmikumaran & Sridharan analyse the tax deduction challenges arising when employee stock option plans are implemented via trusts