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?

Italy’s Supreme Court has issued a controversial decision on the requirements necessary to benefit from withholding tax (WHT) exemptions on profits distributed to companies resident in other EU member states. Chiomenti’s Paolo Giacometti and Raul-Angelo Papotti discuss what this means for the Parent-Subsidiary Directive.

Italy has one of Europe’s most active leveraged buyout markets, and local regulators have been eager to ensure such activity is sufficiently taxed. LED Taxand’s Guido Arie Petraroli and Patrizio Braccioni explore recent legislative tax changes in Italy and Europe and how this will impact private equity activity.

Taxing multinationals in the digital services sector has remained a complex international challenge for local governments limited in their jurisdictional capabilities. Tremonti’s Lorenzo Piccardi, Simone Zucchetti and Armando Tardini discuss how Italy is facing these challenges through regulatory developments surrounding permanent establishments and web taxes.

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

Teresa Teixeira Mota and André Vilaça Ferreira of VdA discuss the implications of a binding decision regarding the application of double tax treaty provisions to payments made by Portuguese companies to foreign partnerships

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