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

As Switzerland passes wide-scale tax reform, local tax authorities are increasingly focusing on intangibles and intellectual property (IP) audits as part of a two-pronged approach in tackling tax evasion. Tax Partner’s Caterina Colling-Russo and René Matteotti discuss the focus.

After Swiss tax reform failed to secure public support in 2017, lawmakers have revised key tenants to ensure it passes when it goes to a second referendum, this time in May 2019. Lenz & Staehelin’s Jean-Blaise Eckert and Frédéric Neukomm discuss the potential impact on corporations and shareholders.

As Switzerland harmonises its corporate tax regime with international standards, the number of available tax incentives for businesses will diminish, while the effective tax rate will rise. EY Switzerland’s Kersten Honold and Kilian Bürgi discuss how cantonal ‘tax holidays’ provide an alternative to maintain rates below 10%.

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

Edouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers

Justyna Bauta-Szostak and Gniewomir Parzyjagła of MDDP say the new guidance on withholding tax is a step forward for businesses operating across borders and overseas funds investing in Poland

Raquel Maurício of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines recent Portuguese VAT changes aimed at urban rehabilitation and why legal uncertainties risk undermining the housing goals they aim to support