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

Post-BEPS, TP controversy has affected all industries. Deloitte’s Ralf Heussner, Aydin Hayri and Juan Ignacio de Molina explore the impact on the financial services, life sciences and automotive industries.

Mexico’s northern border has always been a contentious zone given its proximity to the world’s largest consumer market: the US. Roberto Padilla Ordaz and Jorge Ramón Galland Ríos of Chevez Ruiz Zamarripa outline the latest taxpayer incentives introduced in the region.

Chinese governmental authorities remain supportive of rational, well-ordered and healthy outbound investment. Michael Wong, Joseph Tam, Karen Lin, Cloris Li and Alan O’Connor look at key domestic tax and regulatory measures implemented to enhance the competitiveness of Chinese outbound investment on the global stage, including under the Belt and Road Initiative (BRI).

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

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