Expert Analysis

Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test

Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol

Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions

Factors such as a saturated market and challenging economic headwinds are threatening to bring an end to the SaaS ‘sugar rush’. Niall Kiernan of Vertex considers how businesses in this sector can prepare.

Kyu Dong Kim, Min Young Sung, Joon Yung Jo and Ellie Jin of Yulchon report that foreign companies receiving Korean-sourced income are now required to disclose information about their financials and investors to access treaty benefits.

The clock is ticking on the implementation of the OECD’s pillar two proposals. Phil Myers considers the challenges for companies, the changing role of tax professionals, and how a technology-based solution could help.

Romain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Jakub Warnieło and Agnieszka Walska of MDDP outline the tax risks attracting the greatest scrutiny in Poland and explain how foreign investors can reduce audit exposure through proactive compliance

Anna Misiak, Rafał Sidorowicz, and Agnieszka Telakowska-Harasiewicz of MDDP explain how Poland’s new labour inspection framework affects foreign employers and why flexible workforce models remain available when supported by appropriate governance and compliance measures

Joana Lobato Heitor and Bárbara Miragaia of MFA Legal & Tech explain how recent EU judgments are strengthening foreign investors’ claims for refunds of Portuguese withholding tax