Expert Analysis

Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems

The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world

Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners

Join ITR and Thomson Reuters on May 28 for the second webinar of a three-part series on e-invoicing and hear how businesses can strategically manage measures such as the VAT in the Digital Age proposal

Gain essential insights into continuous tax controls by joining ITR and Thomson Reuters on April 30 for the first webinar of a three-part series on streamlining e-invoicing compliance in a digital-first world

Businesses must embrace a new tax paradigm with Indonesia’s adoption of pillar two. Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explore the impact on compliance, transfer pricing, and tax incentives

Mikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters

With South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy

Monika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici comment on a judgment regarding the withholding tax exemption for outbound interest on financing received indirectly by foreign investment funds as beneficial owners

Francesco Di Bari of Alma LED explains how an Italian Supreme Court ruling marks a pivotal shift in the tax treatment of interest on indirect lending, restoring key exemptions for qualified foreign institutional investors

Niklas Elofsson and Vsevolod Konyshev of KPMG Sweden draw on their experience to explore how successful tax functions implement structured transformation strategies to manage complexity and deliver long-term value