Expert Analysis

Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict

If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues

TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist

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.

The past three years have seen significant changes to the Colombian tax framework, generally constituting a convergence with international tax concepts. Ximena Zuluaga and Luis Orlando Sánchez, of EY, explore the changes introduced by the 2012 tax reform and associated regulations released at the end of 2013 and assess the scope for further reform measures.

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

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Magdalena Marciniak and Magdalena Dymkowska of MDDP explain how Poland is sharpening its transfer pricing audits, considering periodic reviews for the largest taxpayers, and increasing the use of tools designed to foster certainty

Fernando Matesanz of Spanish VAT Services examines how the opinion delivered in case C-515/24 addresses whether Spain could limit VAT deduction rights at the moment of its EU accession under the standstill clause

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status