Expert Analysis

HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented

In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses

Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies

Ronnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work

Sameer Nurmohamed, partner, Deloitte Legal Canada

George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)

Global tax rules are changing, and changing rapidly. The final reports on the Base Erosion and Profit Shifting (BEPS) Action Plan have been released by the Organisation for Economic Cooperation and Development (OECD) and endorsed by the G20. These reports on the 15 BEPS Action Points recommend significant changes in international tax laws and treaties. Due to the unique global alignment on the matter, BEPS is the most comprehensive change in international taxation in history. Attention has turned to the actions that are being taken by countries in response to these recommendations.

There is no such thing as a quiet year for China's tax system.

The focus of many of the articles in this guide on issues tied to the multilateral efforts to counter tax base erosion and profit shifting (BEPS) shows that taxpayers across Latin America are keeping a close watch on global developments.

India has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime

Fabian Abi Cakra and Erviyanti Adam of GNV Consulting explain how Indonesia’s revised MSME tax regime preserves the preferential 0.5% rate while tightening eligibility criteria and introducing new anti-avoidance measures aimed at business fragmentation