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

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 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.

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%.

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