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

Chile plans to overhaul its tax regime by amending corporate income tax provisions, capital gains tax rules, permanent establishment provisions and introduce a digital services tax. Sandra Benedetto and Gregorio Martínez of PwC Chile explain the changes.

Withholding taxes are commonly applied in Switzerland to certain debt issues, even though many foreign jurisdictions have abolished such taxes. Bär & Karrer’s Christoph Suter and Susanne Schreiber discuss how Swiss issuers are increasingly limiting their tax exposure through foreign subsidaries and observing lender limits.

Switzerland has accepted a greater number of exchange of information (EOI) requests from global actors since 2009, harmonising the otherwise private nation’s banking policies with the OECD’s more transparent standards. Lenz & Staehelin’s Jean-Blaise Eckert and Frédéric Neukomm discuss the changes.

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