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

A three-part weekly series begins with Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte sharing insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

Ralf Heussner, Alison Lobb, and Yvonne Weigelt from Deloitte’s global transfer pricing network preview a series based on an interview with the head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

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

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