Expert Analysis

Switzerland is one of the founding members of the OECD and actively contributes towards the attainment of the organisation’s goals, explain Christoph Suter and Susanne Schreiber of Bär & Karrer. In continuation of this commitment, the country pledged its full support to the OECD/G20 BEPS project and actively contributed to the 15-point plan to address base erosion and profit shifting.

Judging by the speeches at the World Economic Forum in Davos, political and business leaders are concerned by the changing dynamics of international tax competition and there can be no doubt that the ‘race to the bottom’ is on.

Litigation between taxpayers and authorities is growing worldwide, but a successful outcome is never easy for any party involved in a conflict. Anjana Haines investigates why tax disputes are rising and how to potentially ease the burden.

João Riscado Rapoula and Hugo Leonardo of VdA analyse the new Construir Portugal scheme, outlining how targeted tax incentives are reshaping the country’s landscape for affordable housing investment and residential real estate

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

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

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse a recent ruling of the Italian Supreme Court that clarifies the conditions for the deductibility of costs related to intercompany services

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