Expert Analysis

Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage

Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities

The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment

Interview with Bernard Mofokeng, head of tax controversy (South Africa), Deloitte Africa tax and legal

Liliana Piedade and João Filipe Rodrigues of Cuatrecasas argue for a substantive interpretation of Portugal’s stamp duty exemption on guarantees provided by financial institutions, credit institutions, and similar entities to counterparts of an identical nature

Amit Maheshwari and Manish Garg of AKM Global provide a guide to the UAE’s nascent regulatory framework for transfer pricing and offer strategies to ensure compliance and the maintenance of proper documentation

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

Shaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues

Gabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform test phase, pending regulations, and key concerns for businesses

Chris Hall of Vertex explains how e-invoicing is becoming essential for multinational businesses, enabling compliance, operational efficiency, and friction-free participation in global trade amid increasingly digital tax regimes

Fernando Matesanz of Spanish VAT Services explains how the General Court has clarified the application of triangular transaction rules in intra-EU supply chains involving four parties