Expert Analysis

Managing tax risk is higher on the agenda for multinationals than ever before. One only needs to tot up the damning tax-related headlines in the mainstream press last year to see why. Lesley Holstead, who has spent much of her career helping multinationals manage tax risk, shares her experience in creating a successful strategy.

The Conseil d’Etat recently handed down a judgment on the deductibility rules for input VAT on expenditure incurred by holding companies active in the management of their subsidiaries. Sonia Bonnabry, of LeXcom, analyses what the decision means for taxpayers.

The IRS is unhappy with multinationals exploiting cross-border differences in treatment of debt and equity for tax gains and is throwing more resources into preventing it. But Hewlett Packard, Scottish Power and PepsiCo were all challenged in the US Tax Court over debt-equity issues last year and two of them emerged victorious. Joe Dalton explains why such structures are still a valid and beneficial option for taxpayers and how to prepare your case if the IRS comes calling.

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