Expert Analysis

The disparity between China’s rapidly developing and evolving digital economy and its largely traditional economy-based tax administration system is growing, and is creating challenges for both the tax authorities and taxpayers. Sunny Leung, Benjamin Lu, Jessie Zhang, and Grace Luo explore the issues.

As companies embark on overseas investment and projects under China’s Belt and Road Initiative (BRI), they are increasingly encount­ering tax issues in emerging and developing countries. Michael Wong, Joseph Tam, Alan O’Connor, Karen Lin, and Cloris Li look at key corporate tax issues they may face, and how the SAT is supporting Chinese companies to navigate through these overseas tax challenges.

Widening the tax rules to address the evolving digital economy is a regular talking point for many. Channing Flynn, partner and global digital tax leader, and Jennifer Cooper, senior manager of international tax services, at EY highlight what’s next on the agenda.

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