Juan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.

Alison Lobb and Howard Osawa of Deloitte explore potential areas of controversy arising from the G20/OECD’s pillar one and pillar two project and considerations to manage disputes and potential double taxation.

Manisha Gupta, Iva Georgijew and Bhupendra Kothari of Deloitte discuss the transfer pricing risks that may arise due to business disruptions caused by COVID-19 with recommendations on how to manage those risks.

Endy Arya Yoga and Dewa Gede Dharma Kusuma of GNV Consulting outline Indonesia's temporary VAT relief for domestic economy-class airline tickets and new legal protections for investors in special debt securities

India has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime

The success of ViDA in creating a harmonised digital reporting framework hinges on EU member states simplifying national VAT reporting obligations, says Fernando Matesanz of Spanish VAT Services

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments

Bárbara Miragaia of MFA Legal & Tech argues that the regime’s restrictive eligibility rules and limited relief for intra-group transactions may constrain its practical benefits

Renata Colafêmina and Rafaela Calçada da Cruz of Machado Associados comment on how the consumption tax reform could affect the taxation of carbon assets and environmental projects

Gabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform implementation phase and concerns about pending regulation

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance

Kathya Capote Peimbert of Vertex examines how continuous transaction controls expose under‑addressed intercompany transaction risks, and outlines the approach multinationals should take to ensure consistent VAT treatment and improve audit defensibility