Expert Analysis

Bill Maclagan, QC, partner at Blake, Cassels & Graydon, looks at the comments of the Canada Revenue Agency (CRA) on derivative forward agreements and exchangeable share transactions, and shares insights as to what the authorities are expecting from taxpayers.

Larissa Neumann, partner at Fenwick & West, assesses the transfer pricing landscape in the US, looking at authority attitudes and areas of focus based on recent dispute cases, and points to the need for consensus on the transfer pricing aspects of the OECD’s project to tackle base erosion and profit shifting.

In the first of his regular monthly updates, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, looks at why countries are enacting unilateral legislation to limit interest deductibility, the shift in focus from eliminating double taxation to eliminating non-taxation, and why, as a result, double taxation via interest limitations is here to stay.

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