Expert Analysis

Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model

MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches

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.

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.

Transatlantic deals between the US and Europe have fallen since the end of 2017, although activity levels in the US domestic market have increased. Can this be attributed to US tax reform? And what has US tax reform meant for transatlantic M&A more generally? EY’s James Hume and Joe Toce consider these questions and the broader impact on due diligence, financing and post-acquisition integration.

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

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

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Patrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines

Nicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications