Expert Analysis

Hong Kong’s Commissioner of Inland Revenue (CIR) announced during a public seminar in February 2012 that the Inland Revenue Department (IRD) is preparing to launch an advance pricing arrangement (APA) programme starting in April 2012. Philip Wong and Petrina Chang of Deloitte in Hong Kong provide a break-down of the new facility.

The OECD published a discussion draft on the future of permanent establishments (PE). Pallavi Bakhru & Nidhi Gupta of Walker, Chandiok & Co provide an insight into the Indian perspective and use examples on how the country interprets the definition of PE.

José Carlos Silva and Eduardo García Ruiz of Chevez, Ruiz, Zamarripa y Cia outline the opportunities available to taxpayers when using global depositary notes (GDNs) in Mexico.

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

Mithilesh Reddy of Steadfast Business Consulting says multinationals must adopt proactive governance and robust compliance practices as the region’s transfer pricing environment develops at pace

Mithilesh Reddy of Steadfast Business Consulting outlines how the qualified domestic minimum top-up tax is reshaping multinational tax planning, compliance, and strategic operational structures in the UAE

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