Expert Analysis

From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa

ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons

Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns

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.

Switzerland has accepted a greater number of exchange of information (EOI) requests from global actors since 2009, harmonising the otherwise private nation’s banking policies with the OECD’s more transparent standards. Lenz & Staehelin’s Jean-Blaise Eckert and Frédéric Neukomm discuss the changes.

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.

Romain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Adrian Rus and Georgiana Bizdrigheanu of EY Romania explain how the country’s tax authorities are reshaping transfer pricing compliance, dispute prevention, and dispute resolution – with implications well beyond Romania’s borders

Balazs Majoros and Oleg Tupchii of Deloitte Luxembourg examine the Singapore Telecom case and its implications for intra-group financing, implicit support, parental guarantees, and arm’s-length interest rates

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the international tax implications of employees’ increasing global mobility, focusing on permanent establishment and transfer pricing issues, with insights from Italy