Expert Analysis

Michael Lennard, acting secretary, UN Committee of Experts on International Cooperation in Tax Matters, writing in a personal capacity, discusses the UN Practical Transfer Pricing Manual for Developing Countries, which was publicly launched on May 29.

Cagla Bekbolet runs the financial officers’ practice at global executive search firm Egon Zehnder. Multinationals who use her to find their next tax director are, more and more, looking for a new kind of professional who can deal with the challenges presented by the demand for increased transparency and the need for the management of a company’s tax affairs to enhance, or at least, not harm, its reputation. Salman Shaheen speaks to Bekbolet to find out what new skills are needed and where they can be found.

An understanding of the domestic limitation of benefit provisions applicable to the tax treaties entered into by some African jurisdictions is essential if transaction pitfalls are to be avoided, warn Leon Steenkamp and Stephen Hales, of Ernst & Young.

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