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)

Stephan Habisch and Andreas Göttert of Deloitte Germany analyse the latest difficulties arising from global trade frictions and supply chain challenges, and explain possible approaches using transfer pricing theory applied to the automotive industry

Szymon Wlazłowski and Igor Fudali of Deloitte Central Europe explain why transfer pricing economic analyses must now adapt to inflation, supply chain shocks, and trade tensions to remain robust and defensible

Richard Schmidtke, Heike Schenkelberg, and David Sauer of Deloitte Germany explore how changing tax incentives, trade barriers, and evolving transfer pricing regulations affect life sciences and healthcare companies operating complex, global value chains

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments

Bárbara Miragaia of MFA Legal & Tech argues that the regime’s restrictive eligibility rules and limited relief for intra-group transactions may constrain its practical benefits

Gabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform implementation phase and concerns about pending regulation