Expert Analysis

In the hype of the BEPS Project, Mexico has been one of the most active countries in applying the concepts of substance, transparency and consistency, write Simón Somohano and David Cárdenas of Deloitte.

The key word for the 13th edition of the Latin America guide is transparency, as countries across the region, spurred by numerous international initiatives, begin to collect and share more information than ever before.

The arm’s-length principle establishes that the conditions agreed between two related enterprises in their commercial or financial transactions cannot be different to those made between independent parties, writes Alejandro Paredes Maldonado of Deloitte Chile. If they differ, the profits of those enterprises may change and will be taxed accordingly.

Dave Yaros, tax principal, Deloitte Tax LLP

Governments’ unprecedented access to transactional data is creating new indirect tax challenges for multinationals. Alex Baulf of Avalara summarises key regional developments ahead of a webinar sharing his practice-based insights

Lisa Zajko, indirect tax partner, Deloitte Canada

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

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

André Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny

Samuel Fernandes de Almeida and Ana Rita Carvalho of MFA Legal & Tech explain how a Portuguese binding ruling fuels the emerging dispute with Spain over non-habitual tax residents