Expert Analysis

Heads of tax need to push their teams forward as strategic business advisers to add value across their organisations, says Sandy Markwick

Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede

China’s largest overhaul of its tax administration system in 24 years, featuring enhanced enforcement powers, is underway, says Abe Zhao of FenXun Partners

Interview with Dr Alexander Linn, partner, business tax

Interview with Bernard Mofokeng, head of tax controversy (South Africa), Deloitte Africa tax and legal

Liliana Piedade and João Filipe Rodrigues of Cuatrecasas argue for a substantive interpretation of Portugal’s stamp duty exemption on guarantees provided by financial institutions, credit institutions, and similar entities to counterparts of an identical nature

Mikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters

With South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy

Monika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici comment on a judgment regarding the withholding tax exemption for outbound interest on financing received indirectly by foreign investment funds as beneficial owners

Francesco Di Bari of Alma LED explains how an Italian Supreme Court ruling marks a pivotal shift in the tax treatment of interest on indirect lending, restoring key exemptions for qualified foreign institutional investors

Niklas Elofsson and Vsevolod Konyshev of KPMG Sweden draw on their experience to explore how successful tax functions implement structured transformation strategies to manage complexity and deliver long-term value