Expert Analysis

Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout

Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Samuel Gordon and Ralf Heussner of Deloitte provide an overview of a series of articles on the impact of three modern trends on value chains, and the implications for transfer pricing.

Samuel Gordon, Ralf Heussner, Vrushang Sheth and Shefali Shah, of Deloitte assess the transfer pricing challenges that result from the intangible assets generated by insurance brands and the digitalisation of the industry.

The attitude of financial services businesses towards flexible working has changed as the benefits are appreciated, but there are ensuing transfer pricing issues, report Priscilla Ratilal, John Leightley, Vrushang Sheth and Benjamin Tausig of Deloitte.