Eric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations.

Paul Riley, Shaun Austin and John Breen preview ITR’s controversy guide, produced in collaboration with global transfer pricing (TP) experts from Deloitte.

Deloitte’s Jacqueline Doonan, Aydin Hayri, Oscar Burakoff and Clarke Norton explore the impact that the economic disruption has had on transfer pricing (TP) controversy in the hospitality, life sciences and consumer products industries.

Hartiadi Budi Santoso and Arip Prastyo Wibowo of GNV Consulting Services summarise the application of the waiver, along with new regulations regarding customs audit and excise audit procedures, and free trade zone customs declarations

Kelvin Yuen of DLA Piper Australia summarises proposed changes to the managed investment trust regime, the deferral of a mooted foreign resident capital gains tax measure, and increased funding for the Australian Taxation Office

S Sriram and Dinesh Kukreja of Lakshmikumaran and Sridharan examine the tax consequences of foreign business reorganisations in India, including indirect transfer rules, statutory exemptions, and treaty benefits for multinational companies

Jian-Cheng Ku, Roland Kleimann, and Jurriaan van Bladel of DLA Piper Netherlands analyse recent case law on key financing functions as an exception to a Dutch interest deduction limitation

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

Gabriel Caldiron Rezende of Machado Associados summarises the general aspects of the recently enacted Brazilian selective tax and explains why taxpayers should already be making preparations before its entry into force in 2027

Sandra Benedetto and Jonatan Israel of PwC Chile provide an overview of a law establishing a new legal concept that aligns taxation with ESG principles, and consider its implications for Chilean companies

Gabriel Caldiron Rezende of Machado Associados summarises the general aspects of the recently enacted Brazilian tax reform and calls on businesses to conduct a thorough assessment of its potential impact

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.

In the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.

Michael Bernard of Vertex says adapting to the US’s challenging tax regime relies on an understanding of what is known as the nexus principle

With 45 states imposing a sales tax, Michael Bernard of Vertex explains the key points to note for European businesses aiming to broaden their market and capitalise on the e-commerce boom in the US

Mark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty

Dinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes

Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg