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

Energy companies using an asset-backed trading (ABT) model can hedge against volatile markets by better controlling their supply chain, but this can also trigger new transfer pricing issues. Deloitte’s Nick Pearson-Woodd and Marius Basteviken discuss.

The OECD has issued new guidance on applying the profit-split method (PSM) in the energy and resources (E&R) sector. But will this see an uptick in its use? Deloitte’s Mark Barker and Aengus Barry discuss.

India’s rapid growth and energy consumption has seen the government simplify public-private investment partnerships in the upstream oil and gas (O&G) sector. Deloitte’s Bhavik Timbadia and Ankit Goel discuss the transfer pricing (TP) implications.

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