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 method a firm employs to merge or acquire a corporation in Mexico carries with it a complex array of tax opportunities and challenges. SMPS Legal’s Ana Paula Pardo and Jorge San Martín Elizondo explore how local and international firms can best position themselves with Mexico’s varied tax framework.

Mexico’s economy has made notable gains in the past decade, bringing opportunities for financially healthy Mexican corporations to exploit leveraged recapitalisations. Galicia Abogados’ Federico Scheffler and Sebastián Ayza discuss the tax implications and impact for mergers and acquisitions (M&A).

In early 2019, Malta implemented both the EU’s anti-tax avoidance directives and multi-lateral instrument (MLI), seeing Malta harmonise a number of its domestic tax regulations. Camilleri Preziosi’s Donald Vella and Kirsten Cassar explore how this will impact local business and multinationals, controlled foreign company rules and exit taxes.

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

Shaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues

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