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

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.

Withholding taxes are commonly applied in Switzerland to certain debt issues, even though many foreign jurisdictions have abolished such taxes. Bär & Karrer’s Christoph Suter and Susanne Schreiber discuss how Swiss issuers are increasingly limiting their tax exposure through foreign subsidaries and observing lender limits.

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