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

The interest deduction rules in relation to Dutch real estate companies are set to change. Jian-Cheng Ku and Thijs Haverbeke of DLA Piper Netherlands discuss the update and provide ideas for mitigating any adverse effects

Teresa Teixeira Mota and Francisco Lencastre Torres of Vieira de Almeida & Associados explain how generative AI and enhanced human understanding can help in-scope Portuguese constituent entities manage the complexities of pillar two compliance

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a transfer pricing-related ruling by the Italian Supreme Court that effectively clarifies the role of OECD guidelines and the ‘best method’ rule