Expert Analysis

KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter

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

Panama, Costa Rica, Nicaragua, El Salvador, Honduras, Guatemala and the Dominican Republic have had uneven responses to the BEPS project. Isabel Chiri, Rafael Sayagues and Alexandre Barbellion of EY explain the current situation and why the BEPS project could lead to undesirable outcomes for the region.

On December 29 2016, the Colombian Congress enacted a new tax reform through Law 1819. This reform substantially modifies many aspects of the Colombian tax system. Jaime Vargas of EY summarises and comments on some of the most relevant changes introduced by the reform.

At the beginning of 2013, and after having had a very hard time trying to convince businesses to support the 2012 tax reform, the government promised that it would file a comprehensive tax reform to better articulate the tax system and in this way avoid the need of making reforms every other year to deal with budget constraints, writes Jaime Vargas, tax managing partner and international tax services leader at EY Colombia.

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