Expert Analysis

Addressing tax base erosion and profit shifting (BEPS), as well as certain other instruments such as dual loss consolidation, is currently one of the most central points of concern for international tax legislation say Claus Herfort and Alke Fiebig of PwC, particularly for the respective bodies of the EU and the OECD.

Tax planning in M&A transactions starts long before a transaction appears on the horizon and lasts long after the deal is completed. Key challenges for the tax function are explored by Christoph Huber and Napoleão Dagnese of OC Oerlikon, a traditional Swiss multi-industries conglomerate with a footprint in 34 countries, 160 sites and with several M&A deals recorded.

From the perspective of a divesting group, tax is all too often just viewed as a cost and potential barrier to a successful exit. This is understandable given the often narrow focus on the impact of tax in a divestment but by broadening this perspective there is significant incremental commercial value that can be realised. Richard Clarke and Todd Miller of EY discuss.

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