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

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.

Most banks make it a policy not to provide tax advisory services, even though there are no regulatory prohibitions to do so in Switzerland, the UK or US. But as tax considerations become increasingly important in any investment strategy, Deloitte Switzerland’s Brandi Caruso and Karim Schubiger discuss the viability of banks providing such an explicit value-add.

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