Expert Analysis

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

Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

Join ITR for a free webinar on September 30 as insightsoftware, with guest speakers from Alvarez and Marsal Tax, explores how evolving technology is reshaping talent strategies and how organisations can close a skills gap

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Gabriel Caldiron Rezende of Machado Associados examines the debate concerning the inclusion of CBS and IBS in the ICMS taxable base and considers whether increased litigation may be on the horizon

Raghav Rajeev and Nimrah Ali of Lakshmikumaran & Sridharan analyse the approaches taken by taxpayers and Indian judicial bodies on contested tax payments under the country’s goods and services tax law

Bernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address