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 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.

Taxing cryptocurrencies and assets digitally conceived and transferred has little precedence globally. In Malta, the Commissioner for Revenue has recently released guidelines for local authorities to understand their tax liability, particularly as they grow in European popularity. Camilleri Preziosi’s Donald Vella and Kirsten Cassar discuss the VAT, income tax and stamp duty obligations from a Maltese perspective

Chile plans to overhaul its tax regime by amending corporate income tax provisions, capital gains tax rules, permanent establishment provisions and introduce a digital services tax. Sandra Benedetto and Gregorio Martínez of PwC Chile explain the changes.

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