Features

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.

Southeast Asia is a major energy and resource destination market, but its varied geopolitical structure gives rise to a number of unique TP challenges. Deloitte’s Jee Chang See and Avik Bose discuss.

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.

Transfer pricing (TP) litigation surrounding the energy and resources (E&R) sector has increased drastically over the past two years. While determining the owner of the commodity price risk has drawn increased attention, Deloitte’s Mark Barker and Aengus Barry discuss how tax authorities predominantly employ the comparable uncontrolled price (CUP) method in any TP dispute.

Offshore marketing hubs are becoming increasingly commonplace for Australian resource firms in Asia. Deloitte’s John Bland and Milla Ivanova discuss what factors may trigger increased regulatory scrutiny for a multinational under the Australian Taxation Office’s (ATO) risk ratings.