Expert Analysis

Matthew Greene, a solicitor at PwC Legal in London, looks at what a recent UK Court of Appeal decision can tell taxpayers about the courts’ approach to interpreting tax treaty provisions.

Foreign companies with activity in the US are often surprised that such activity may trigger both federal and state-level tax implications. Joel Walters, Maureen Pechacek and Todd Roberts of PwC US explore how state tax exposure may vary substantially, potentially resulting in significant state tax liabilities even when little to no US federal tax obligations exist.

While many countries, such as the UK, actively try to attract investment by promoting an open for business agenda epitomised by offering attractive tax benefits such as a competitive corporate income tax rate and a patent box scheme, the BRICs countries – and Brazil in particular – are managing to attract investment in spite of their unattractive and complex tax regimes. Matthew Gilleard finds out why.

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