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

The OECD has issued new guidance on applying the profit-split method (PSM) in the energy and resources (E&R) sector. But will this see an uptick in its use? Deloitte’s Mark Barker and Aengus Barry discuss.

India’s rapid growth and energy consumption has seen the government simplify public-private investment partnerships in the upstream oil and gas (O&G) sector. Deloitte’s Bhavik Timbadia and Ankit Goel discuss the transfer pricing (TP) implications.

As resource-rich Middle Eastern governments suffer a decline in oil revenues, many governments are reforming transfer pricing (TP) regulations to limit capital flight. Deloitte’s Shiv Mahalingham, Alena Kovalova and Claire Boushell discuss the regional regulatory trends.

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