Expert Analysis

The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests

The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation

A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements

Senior Deloitte tax practitioners explain how a hybrid e-invoicing model can enable multinationals to step off the compliance treadmill while balancing global consistency with local requirements

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

Romain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation

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

Francisco Cabral Matos, Hugo Leonardo, and Margarida Campelo of VdA examine how corporate income tax and VAT planning, vehicle selection, and structuring choices can materially affect returns on Portuguese real estate investments

Emanuel Băncilă of Băncilă, Diaconu și Asociații SPRL, part of the EY Law global network, questions the legality of an ‘unprecedented volume of unexpected audits’ for 500 large taxpayers in Romania

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse Italy’s cross-border tax and transfer pricing rules under DAC3 and DAC8