Expert Analysis

From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025

In-house teams that want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues

Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies

Johan Van der Paal and Bram Fouache of Deloitte Belgium explain how the EU’s VAT in the Digital Age Directive is reshaping VAT compliance across Europe, and how businesses can prepare for digital reporting and e-invoicing reforms

Join ITR and Thomson Reuters on June 25 as a three-part webinar series concludes with real-world insights into how businesses are managing the e-invoicing transition and the strategies enabling global compliance

Sudin Sabnis and Siddhesh Khandalkar of Lakshmikumaran and Sridharan explore how context shapes the interpretation of undefined terms in tax treaties, balancing treaty text, domestic law, and diplomatic intent

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

Carlos Ayub of Deloitte Brazil explores the government’s move to regulate advance pricing agreements as the country aligns its transfer pricing framework more closely with OECD standards

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados analyse the application of Brazil’s federal tax on industrialised products to intragroup goods transfers, after a ruling that addressed alleged tax planning abuses

Ricardo Seabra Moura of Morais Leitão, Galvão Teles, Soares da Silva & Associados analyses how Portugal’s withholding tax rules on interest payments may unlawfully discriminate against companies based in European Economic Area countries

Łukasz Kosonowski and Szymon Konieczny of MDDP examine how Poland’s Estonian-style corporate income tax regime is offering increasing benefits to domestic and foreign investors seeking deferral and lower dividend withholding tax