Expert Analysis

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

MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

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

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

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

Claudia Sofianu and Dan Răut of EY Romania discuss the growing challenges of cross-border teleworking, highlighting the complexities of taxation rights and the need for clearer and more unified EU regulations

Endy Arya Yoga and Nanda Atsatalada of GNV Consulting summarise legislative updates concerning corporate income tax reduction facilities, bad debt expense deductions from gross income, and implementation of the Core Tax Administration System

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss a recent decision by the Brazilian Supreme Court that ensures proportionality in tax penalties and strengthens legal protections for businesses