Expert Analysis

The Ruling Committee of the Belgian Ministry of Finance has recently published an “Advice” which includes new guidelines for the application of anti-abuse rules on various types of business restructuring, such as a (partial) demerger and the contribution of a branch of activities. Geert De Neef of Lydian explains how these guidelines will impact taxpayers.

Legislators have recently reacted to popular thinking that banks and their investors should be the ones paying for losses from banking risk materialising. Hans-Ulrich Lauermann and Kathryn Struve of PwC discuss bank levies in respect of European and US legislators.

On March 14 2014, the OECD released a discussion draft on treaty abuse under its Action Plan on Base Erosion and Profit Shifting (BEPS). Marc Sanders of Taxand provides guidance on the BEPS project’s impact on the private equity sector.

India’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV

Join KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

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

Nicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services