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

Hong Kong has seen substantial changes to its tax landscape in 2018. Curtis Ng, Michael Olesnicky, John Timpany and Ivor Morris discuss Hong Kong’s tax changes for transfer pricing (TP) and research and development (R&D) aimed at enhancing Hong Kong’s competitiveness and driving its economic growth.

Mexico has established seven special economic zones (SEZs) via special decrees and regulations with several more to come. Raúl Morales Medrano, partner at Chevez Ruiz Zamarripa, discusses the main benefits for taxpayers wanting to operate within these areas.

During 2017 and 2018 the Mexican Stock Exchange witnessed the placement of securities issued by the first two Mexican special purpose acquisition companies (SPACs). Alberto Alvarez and Moisés Gutiérrez of Chevez, Ruiz, Zamarripa y Cia., address some aspects of the operation of said companies, as well as the tax implications that could arise for investors as a result of participating in a Mexican SPAC.

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