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

Southeast Asia is a major energy and resource destination market, but its varied geopolitical structure gives rise to a number of unique TP challenges. Deloitte’s Jee Chang See and Avik Bose discuss.

Transfer pricing (TP) litigation surrounding the energy and resources (E&R) sector has increased drastically over the past two years. While determining the owner of the commodity price risk has drawn increased attention, Deloitte’s Mark Barker and Aengus Barry discuss how tax authorities predominantly employ the comparable uncontrolled price (CUP) method in any TP dispute.

Energy companies using an asset-backed trading (ABT) model can hedge against volatile markets by better controlling their supply chain, but this can also trigger new transfer pricing issues. Deloitte’s Nick Pearson-Woodd and Marius Basteviken discuss.

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