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

Switzerland receives an unprecedented number of information exchange requests every year by foreign countries. Burckhardt Law’s Rolf Wüthrich explores how the private banking state is amending its exchange obligations around share rights and corporate ownership in a bid to harmonise its laws with international norms.

Most banks make it a policy not to provide tax advisory services, even though there are no regulatory prohibitions to do so in Switzerland, the UK or US. But as tax considerations become increasingly important in any investment strategy, Deloitte Switzerland’s Brandi Caruso and Karim Schubiger discuss the viability of banks providing such an explicit value-add.

Energy multinationals have complex, international supply chains that contract a host of specialist companies in the process of bringing vital commodities to market, making intellectual property attribution ambiguous. In this primer, Deloitte’s Nick Gaudioso, Randy Price, Nadim Rahman and John Wells give an overview of the energy excavation and production process to understand the tax ramifications.

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