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

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.

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.

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.

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