Expert Analysis

Mike Bernard, former Microsoft tax counsel, talks to ITR about his experience at Microsoft, how the tax department functioned, and how he will help MNEs use data to be audit-ready in his new role at Vertex.

The OECD’s David O’Sullivan opened ITR’s Indirect Tax Forum by talking about the role which web companies can play in collecting VAT and GST. Subscribers and delegates can download his presentation – and those of other speakers, including the EU’s Maria Teresea Fábregas – here.

Businesses love certainty. It allows them to plan and act on short, medium, and long-term strategies. The unexpected brings operational complexities they do not need. Recently, as taxation of the digital economy gathers pace it is a case of ‘expect the unexpected’ for digital businesses operating globally. Taxamo’s Iman Deschâtres and JP McCarthy explore the topic.

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

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

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

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Mithilesh Reddy of Steadfast Business Consulting outlines the key transfer pricing compliance risks, pillar two impacts, and structuring priorities for multinational enterprises under the UAE’s new R&D tax credit regime

Kathya Capote Peimbert of Vertex examines how continuous transaction controls expose under‑addressed intercompany transaction risks, and outlines the approach multinationals should take to ensure consistent VAT treatment and improve audit defensibility

Aditya Wicaksono and Reza Farhan of GNV Consulting outline new Indonesian tax provisions concerning penalty waivers, filing extensions, and compliance protections introduced under recent regulations supporting the roll-out of the Coretax system