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

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici analyse the options excercised and choices made by Italy when transposing the provisions of the Public Country-by-Country Reporting Directive

The Supreme Federal Court has returned to a case that could have a huge economic impact on the federal government, report Paulo Victor Vieira da Rocha and Camila Montenegro Cruz of VRMA Advogados

Magdalena Marciniak and Agnieszka Krzyżaniak of MDDP consider whether two recent rulings indicate that Polish taxpayers can look forward to a more positive landscape for transfer pricing adjustments