Expert Analysis

EU Competition Commissioner Margrethe Vestager, who joins the ranks of the Global Tax 50 for the fifth year in a row and took top spot in last year’s ranking, has had a quieter 12 months in 2017 compared to previous years. But that’s not to say multinationals aren’t still trembling with fear at the thought of being faced with state aid allegations from the determined commissioner.

The phrase ‘Paradise Papers’ evokes images of tropical offshore islands with palm trees and a P.O. address for multinationals and high-net-worth individuals. The list of celebrities involved in one way or another is almost endless. Shakira, Madonna, Keira Knightly, the Queen, Prince Charles, the estate of the late Michael Hutchens, Justin Timberlake, and Amitabh Bachchan. We picture Lewis Hamilton in a private jet.

Richard Murphy came up with the idea of country-by-country reporting (CbCR) in 2003 and his vision reached a milestone this year, earning him a top-10 spot in this year’s Global Tax 50.

Lisa Zajko, indirect tax partner, Deloitte Canada

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

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