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?

After Swiss tax reform failed to secure public support in 2017, lawmakers have revised key tenants to ensure it passes when it goes to a second referendum, this time in May 2019. Lenz & Staehelin’s Jean-Blaise Eckert and Frédéric Neukomm discuss the potential impact on corporations and shareholders.

As Switzerland harmonises its corporate tax regime with international standards, the number of available tax incentives for businesses will diminish, while the effective tax rate will rise. EY Switzerland’s Kersten Honold and Kilian Bürgi discuss how cantonal ‘tax holidays’ provide an alternative to maintain rates below 10%.

Switzerland receives an unprecedented number of information exchange requests every year by foreign countries. Burckhardt Law’s Rolf Wüthrich explores how the private banking state is amending its exchange obligations around share rights and corporate ownership in a bid to harmonise its laws with international norms.

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