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

While US tax reform may not have affected merger and acquisition (M&A) activity explicitly, a change in laws surrounding controlled foreign corporations (CFCs) will see a number of new tax considerations emerge for US buyers and sellers. Fenwick & West’s Adam Halpern and William Skinner discuss how these changes might influence cross-border M&A activity.

Switzerland’s federal tax administration has published an update on its tax ruling practice for federal taxes, withholding taxes (WHT) and stamp duty as it nears a second referendum on corporate tax reform. burckhardt Switzerland’s Rolf Wuethrich explores how these may affect tax structuring and merger and acquisition (M&A) sentiment.

China has implemented venture capital (VC) tax rules at the same time economic substance requirements for key offshore centres have been introduced. KPMG’s Michael Wong, Christopher Mak and Alan O’Connor highlight the key considerations for businesses.

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

Magdalena Marciniak and Magdalena Dymkowska of MDDP explain how Poland is sharpening its transfer pricing audits, considering periodic reviews for the largest taxpayers, and increasing the use of tools designed to foster certainty

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