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

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.

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