Expert Analysis

Mexican tax rules dealing with transfer pricing adjustments entered into force on January 1 2017. These rules deal only with primary adjustments and all the formalities related to them, especially those to meet the requirements for deductions. Primary adjustments can even be recognised on a cashless basis. Unfortunately, at this stage secondary adjustments are not covered in these rules. Ricardo Rendón and Yoshio Uehara explain the changes.

India’s recent renegotiations of its agreements on the avoidance of double taxation (DTAs) has made fundamental changes to how favoured gateways are used for investing in India. Amelia Schwanke explores the catalysts that initiated the renegotiations and the new treaty structures that have replaced outdated policies.

Tax considerations will never make a deal, but they certainly can break a deal. Laurence Field, a senior tax and corporate business partner at national audit, tax and advisory firm Crowe Clark Whitehill, reflects on the M&A tax landscape that evolved through 2016 and looks ahead to assess what businesses need to know if they are planning to get a transaction over the line in 2017.

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Raghav Rajeev and Nimrah Ali of Lakshmikumaran & Sridharan analyse the approaches taken by taxpayers and Indian judicial bodies on contested tax payments under the country’s goods and services tax law

Bernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address

Tiago Marreiros Moreira, Rita Simão Luís, and Nadine Gomes of VdA analyse how recent EU VAT and energy tax developments shape electric mobility, highlighting opportunities from CJEU rulings and challenges of multi-layered tax frameworks