Expert Analysis

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

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

Increased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan.

Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.

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

Nicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications

Inês Dias Cardoso of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the measures and the potential next steps, with a VAT reduction on construction works at the forefront of developments

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