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

John Gu, Chris Mak and Fiona He explore the key tax issues and considerations of China inbound M&A deals, especially in the education and real estate sectors, including practical challenges for cross-border transactions in these hot sectors, and how an investor can best get prepared.

The increasing size and sophistication of China’s digital economy, as well as the rapid expansion of Chinese digital economy enterprises into foreign markets, is highlighting a range of complex tax issues, and the importance of policymaker efforts to resolve them. Khoon Ming Ho, Conrad Turley, Sunny Leung, and Mimi Wang explore the issues.

Following years of rapid change to China’s cross-border corporate income tax (CIT) rules and advances in enforcement effectiveness, a more measured approach has recently emerged, reflecting business environment changes and China’s evolved position within the global economy. Chris Xing, Conrad Turley, Grace Xie, and William Zhang, trace the latest trends.

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

Fernando Matesanz of Spanish VAT Services analyses a new royal decree, its implementation timetable, and the first points of tension with the EU’s VAT Directive

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