Expert Analysis

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows

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

Join ITR and KPMG China at 10am BST (5pm Beijing time) on April 18 2024 for an analysis of the tax treatment of indirect share transfers in China, and insights into potential developments

Interview with Jo-Anne Anderson, partner, Deloitte Canada

Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte conclude their summary of an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration

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

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

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

Adrian Rus and Georgiana Bizdrigheanu of EY Romania explain how the country’s tax authorities are reshaping transfer pricing compliance, dispute prevention, and dispute resolution – with implications well beyond Romania’s borders

Balazs Majoros and Oleg Tupchii of Deloitte Luxembourg examine the Singapore Telecom case and its implications for intra-group financing, implicit support, parental guarantees, and arm’s-length interest rates

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the international tax implications of employees’ increasing global mobility, focusing on permanent establishment and transfer pricing issues, with insights from Italy