Expert Analysis

As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency

Italy has one of Europe’s most active leveraged buyout markets, and local regulators have been eager to ensure such activity is sufficiently taxed. LED Taxand’s Guido Arie Petraroli and Patrizio Braccioni explore recent legislative tax changes in Italy and Europe and how this will impact private equity activity.

Transatlantic deals between the US and Europe have fallen since the end of 2017, although activity levels in the US domestic market have increased. Can this be attributed to US tax reform? And what has US tax reform meant for transatlantic M&A more generally? EY’s James Hume and Joe Toce consider these questions and the broader impact on due diligence, financing and post-acquisition integration.

While US tax reform may not have affected merger and acquisition (M&A) activity explicitly, a change in laws surrounding controlled foreign corporations (CFCs) will see a number of new tax considerations emerge for US buyers and sellers. Fenwick & West’s Adam Halpern and William Skinner discuss how these changes might influence cross-border M&A activity.

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

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

Rodrigo Winter of PwC Chile outlines the expected effects of the government’s proposal aimed at reviving a residential real estate sector weakened by years of stagnation

Several key rulings clarify the taxation of cross-border payments as royalties with respect to ‘information concerning industrial, commercial or scientific experience’, say S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan

Michael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept