Expert Analysis

Almost everyone agrees the two greatest economic problems facing the US are the growing and unsustainable federal deficit and persistently high unemployment and underemployment. So it is surprising to a long-time tax practitioner that the two leading proposals for corporate tax reform in the US – lowering the corporate tax rate through base-broadening and adopting a territorial tax system – are almost certain to make both problems worse. Jim Ditkoff, senior vice president, finance & tax at the Danaher Corporation, explains why.

Algirdas Šemeta, European Commissioner for Taxation, Customs, Statistics, Audit and Anti-fraud, explains that the proposal for a financial transaction tax (FTT) under enhanced cooperation that the Commission tabled last month is a milestone from at least two perspectives: the tax itself and the procedure used for the tax to become a reality.

There has been a significant rise in controversy around the world in recent years centred on the topic of the beneficial owner test which appears in the dividends, interest and royalties articles of most double tax treaties. Richard Collier, of PwC, explores the work of the OECD in this area to date and what the future holds, calling for greater clarity on the concept.

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

Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied

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