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

China has seen the continued evolution of its transfer pricing (TP) enforcement towards a data-based administrative approach, and away from aggressive audits. Xiaoyue Wang and Choon Beng Teoh explore the latest trends.

Outbound Chinese investment is now taking place against the backdrop of an increasingly robust and supportive TP framework. Xiaoyue Wang, and Choon Beng Teoh examine issues such as the MAP and APA programmes.

China merged its previously separate state and local tax authority systems in 2018. This has provided a basis for improvements in tax administration and services, and required taxpayers to adapt. Michael Li, Tracey Zhang and Fang Wei explore the changes.

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