Expert Analysis

The OECD released a number of reports relating to transfer pricing recently. The draft on intangible assets was released ahead of schedule in June, but the organisation has also produced a draft on safe harbours and memorandums of understanding and another on timing issues. Sophie Ashley considers the practical implications of these reports.

The Canadian government looks set to implement new foreign affiliate dumping rules, but the proposals go further than expected and, if enacted without alterations, would impose severe limitations on Canadian taxpayers, explain Ian Crosbie and Raj Juneja, of Davies Ward Phillips & Vineberg LLP.

Israel has introduced a number of indirect tax changes recently. Tal Hamdi of Herzog Fox & Neeman looks at where they are going.

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

Maria Gouveia of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the most widespread misconceptions surrounding the regime, clarifying its tax deferral mechanism, effective rates, eligibility criteria, and scope

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