Expert Analysis

Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict

If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues

TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist

The Hong Kong SAR government has continued its international focus, introducing incentives to boost competitiveness while taking steps to address global tax avoidance, write Curtis Ng and Ivor Morris.

China has continued to improve access to tax incentives and provide new regulatory support for innovation. At the same time, renewed rigour is being applied to ensure that tax incentives are claimed appropriately. Bin Yang and Nicole Cao detail the landscape.

In 2019, China has pushed reforms to customs supervision and expanded the role of bonded zones, further intensified its use of TP documentation for customs purposes, and sought to refresh key trade agreements. Eric Zhou and Rachel Tao explore the challenges and opportunities.

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

Fernando Matesanz of Spanish VAT Services examines how the opinion delivered in case C-515/24 addresses whether Spain could limit VAT deduction rights at the moment of its EU accession under the standstill clause

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status

Dinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied