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

Jobst Wilmanns and Anodri Suchdeve of Deloitte preview a guide to the latest transfer pricing trends, produced in collaboration between ITR and global transfer pricing industry experts from Deloitte

Join ITR and Wolters Kluwer on September 3 2024 for insights from the latest Wolters Kluwer BEPS Pillar Two Readiness Index Report and advice on the practical steps needed to prepare for pillar two compliance

Join Dhruva Advisors, Taxsutra, and ITR from 12.30pm–2pm BST (5pm–6.30pm India Standard Time) on July 23 to hear expert analysis of the implications of the tax proposals in India’s 2024–25 budget

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

Patrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines

Nicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications

Inês Dias Cardoso of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the measures and the potential next steps, with a VAT reduction on construction works at the forefront of developments