Expert Analysis

John Gu, Yvette Chan and Chris Mak share their insights on encountering practical uncertainties and resolving contentious tax issues when working with clients on merger and acquisition (M&A) transactions in China. They look at how the rapidly changing global tax environment will impact future M&A transactions in China.

In July 2016, China’s State Administration of Taxation (SAT) released Announcement 42, outlining the updated Chinese requirements for contemporaneous documentation. In October, it released Announcement 64, containing revisions to the guidance on the administration of advance pricing arrangements. Chi Cheng, Xiaoyue Wang, Simon Liu, Kelly Liao and Mimi Wang explore the implications.

As China faces rising labour costs and competition from lower cost countries in the region, incentive supply side programmes such as the HNTE scheme and 150% super deduction will help achieve the government’s aim of solid and stable growth for the Chinese economy as it enters its 13th five-year plan. Alan Garcia, Yang Bin, Josephine Jiang and William Zhang highlight the available benefits for R&D.

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

Shaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues

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