Expert Analysis

The Americas have recently seen a number of changes that will impact controversy matters. In December 2017, certain countries passed major tax legislation and there is an increased need for the use of alternative dispute resolution strategies to preclude the need of entering costly and unnecessary litigation. Additionally, funding across the taxing authorities varies greatly and will have an impact on the compliance approaches that the authorities may take to encourage voluntary compliance and deploy resources to the most significant non-compliance. Appropriate funding coupled with recently enacted tax legislation will likely impact the way audits will be conducted in the Americas.

Current trends suggest that multinational organisations will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and are increasingly focusing on not only the technical merit of a tax position but also on its implementation.

In recent times, the most significant change to the tax controversy landscape has been the increase in information provision requirements of taxpayers and the increase in interaction of revenue authorities across the region through information sharing and mutual assistance regimes. In addition, developments in data technology have given rise to greater coordination between different authorities within countries and across the Asia-Pacific region.

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Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

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

Diana Lupu and Ana-Maria Nițu of EY Romania explain when entities subject to the global minimum tax can transition to IFRS, the key benefits and challenges, and the implications for financial reporting and compliance

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia