Expert Analysis

Much time and attention has been devoted to planning for a post-BEPS world, from analysing systems that may need to be adopted to looking at how taxpayer-tax authority relationships are likely to change. But less has been said about the impact of BEPS deliverables on commercial contract documentation and the extent to which such contracts will be scrutinised. Jen Winterhalder, a solicitor in PwC Legal and Latika Sharma, a partner and head of PwC Legal’s intellectual property and commercial contracts team, focus on the importance of matching contract terms to commercial substance, both now and for the future.

Country-by-country reporting (CbCR) has been heralded as the solution to the perceived problem that existing accounts for multinationals do not, and cannot, provide a true and fair view of business. This month’s Brockman brief takes taxpayers through the proposed model CbCR template.

As governments around the world assess the best way to attract – and tax – R&D and intellectual property investment, Giulia Cipollini and Bianca Macrina of Withers in Milan look at the incentives taxpayers can avail in Italy, tracking the nuances of the Italian Patent Box regime from introduction to operation.

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

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

Ahdianto Ah and Aditya Nugroho of GNV Consulting explain recent Indonesian tax reforms affecting business restructurings, treaty access, and enforcement

Ahdianto Ah and Aditya Nugroho of GNV Consulting summarise an extension of the government-borne incentive, new risk-based taxpayer compliance supervision rules, and revised mutual agreement procedure guidelines

Rabie Morsy and Ahmed Khalifa of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt analyse the amendments and guidance, focusing on construction, commodities, exemptions, and practical compliance implications for businesses