Expert Analysis

David Franco, senior Latin America analyst at risk analysis company Maplecroft, explores the evolution of anti-avoidance measures in the region, explaining why multinationals must be prepared for greater scrutiny of their tax affairs in Latin American countries in a trend that follows what is happening in Europe and the US.

Whatever form and acronym it takes (a similar, though narrower, examination was conducted in the 1990s under the banner of harmful tax competition (HTC)), base erosion and profit shifting (BEPS) has been an underlying theme in international taxation for years. But only recently has it risen to the top of the international taxation and political agendas, no doubt accelerated by the tax planning opportunities opened up by the globalisation and mobility of commerce. With Australia poised to take on the presidency of the G20, David Bradbury, Assistant Treasurer until the September election, and a driving force behind much of Australia’s work on tackling BEPS, analyses the impact the country has had on this global debate, looking at the policies his government implemented to get to this stage, and how the new government can take things forward.

Over the past four years, the Indonesian Directorate General of Tax (DGT) has been placing great focus on the tax potential from related-party transactions within multinational groups of companies. The DGT has issued regulations on transfer pricing guidelines, developed its human resources, equipped itself with commercial database, and undertaken audits particularly when there are intercompany transactions. Sri Wahyuni of SF Consulting provides an overview of the changes and explains what taxpayers need to do to guard against audit.

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