Expert Analysis

New data and technology-driven, risk-oriented, tax administration and enforcement approaches by the Chinese tax authorities are compelling taxpayers to up their game. Taxpayers are developing enhanced internal tax risk controls and IT, and engaging with the tax authorities in a collaborative manner. Tracy Zhang, Wei Fang, Anthony Chau, Lilly Li, discuss the latest trends and changes.

Ayesha Lau, Darren Bowdern, Michael Olesnicky, John Timpany and Curtis Ng discuss Hong Kong’s BEPS-related changes after the territory issued a consultation paper to codify and strengthen TP regulations, as well as joining the Multilateral Instrument (MLI). The Hong Kong government is also increasingly using tax policy to encourage economic development.

In 2017, the Taiwan government proposed imposing VAT on foreign enterprises providing e-commerce services to Taiwan individuals, expanding the Taiwan corporate income tax (CIT) nexus rule, and making personal income tax changes. It is also looking at abolishing and replacing the corporate-shareholder imputation tax system. Stephen Hsu, Hazel Chen, Ellen Ting and Betty Lee elaborate.

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