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

Jeklira Tampubolon and Dwipa Abimanyu Dewantara of GNV Consulting outline recent developments on import duties, the Directorate General of Taxes’ follow-up on concrete tax data, e-commerce taxation, and free trade zone regulations

The Italian framework for tax certainty has been reinforced through advance pricing agreements, mutual agreement procedures, and other dispute resolution tools, explain Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente

Jun Au and Eddie Ahn of DLA Piper Australia analyse the Australian Taxation Office’s framework for applying the third-party debt test and debt deduction creation rules under the country’s new thin capitalisation regime