Expert Analysis

Sarah Dahinden

Last year at about this time, we boldly offered our predictions as to the outcomes multinationals could reasonably expect as a result of the efforts of the OECD and the unprecedented energy expended on its base erosion and profit shifting (BEPS) project. We were limited in our vision by the absence of the actual BEPS Action Plan, which was released two days after our publishing deadline. One of our predictions described how, perhaps from the perspective of unintended OECD consequences, countries like Ireland, Switzerland and Singapore could see their economies grow and unemployment dwindle. And they would quietly thank the OECD for its missionary-like zeal in chasing the no-economic-activity brass-plate companies out of places such as the Cayman Islands. If our vision had been just a little sharper last year, we would have added the UK to our shortlist of BEPS beneficiaries.

Nam Nguyen

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

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks

The regime has modernised the taxation of employee equity, but several lingering shortcomings leave room for enhancement, say João Riscado Rapoula, Miguel Gonzalez Amado, and Ana Francisca Ribeiro of VdA

Sandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions