Expert Analysis

Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion

The choice facing governments is not whether to adopt AI in taxation, but how to do so in a way that upholds the principles of tax fairness, writes Neil Kelley

Businesses no longer have a choice when it comes to tax technology transformation. Pavlo Boyko of TMF Group says the question is simply: sink or swim?

In 2018, Hong Kong SAR enacted TP legislation, a significant step in aligning its tax rules with international standards. Karmen Yeung, Irene Lee and Tanya Trantallis set out the key features of the rules.

Intensive work at an international level to erect a new architecture for international tax rules by 2020 will have deep implications for businesses. Conrad Turley and Sunny Leung explore what this might mean for China’s burgeoning digital economy.

The past year has seen a further evolution in China’s tax treaties, in particular in integrating impactful BEPS permanent establishment (PE) changes. The maturity of work on global tax reforms hints at more profound changes ahead, write Chris Xing and Conrad Turley.

Silke Lappe and Karen Smolka of Deloitte Germany examine transfer pricing challenges and governance considerations for cybersecurity and generative AI services, highlighting how emerging technologies are reshaping value chains, compliance demands, and multinational tax approaches

Marco Heuer and Nik Nolden of Deloitte Germany examine how shifts in tariffs, foreign exchange and interest rates, and geopolitical tensions impact multinational groups’ transfer pricing strategies

Stephan Habisch and Florence Müller of Deloitte Germany examine how tariffs disrupt transfer pricing, forcing multinationals to reassess supply chains, manage compliance risks, and explore strategic restructuring to balance challenges with emerging opportunities

Kelvin Yuen and Eddie Ahn of DLA Piper Australia review draft Practical Compliance Guideline 2025/D4, outlining its low-risk zones for cross-border software payments and implications following the recent landmark PepsiCo High Court decision

Edouard Authamayou of Deloitte Luxembourg examines an Administrative Court ruling confirming that tax authorities have full discretion under Section 100a of the General Tax Law to review assessments, with procedural deadlines of critical importance

Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine an Italian ruling and a CJEU judgment addressing when transfer pricing adjustments fall within VAT scope and the conditions for compliance