Expert Analysis

Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment

More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge

As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Mark Martin and Thomas Bettge of KPMG in the US discuss the inclusion of updates to the US Internal Revenue Service’s (IRS) mutual agreement procedure (MAP) and advance pricing agreement (APA) revenue procedures in its priority guidance plan, and consider how successor guidance could further improve the MAP and APA programmes.

Jeklira Tampubolon and Aditya Nugroho of GNV Consulting summarise the recent regulatory developments concerning Indonesian exports, with a particular eye on palm oil and its derivatives.

Oscar Lopez Velarde, Juan Jose Paullada and Alonso Miranda Barceló of Ritch Mueller explain why some Mexican entities will need to reassess the structuring and viability of financing their energy projects following the modification of the thin capitalisation rules in Mexico.