Proposed changes to the Income Tax Act, contained in the 2019 draft Taxation Laws Amendment Bill, were released for comment by the National Treasury on July 21 2019.

Multinationals across all sectors should be ready as fundamental changes to the international taxation system make their way into reality. Alison Lobb, Robert Stack and Paul Riley introduce this special report.

The OECD’s work around the digitalisation of the economy is proceeding at a rapid pace and many multinational enterprises may be surprised at the scope of changes to the international tax framework. These changes could impact all larger multinationals, not just those that consider themselves part of the digital economy.

S Vasudevan and Prachi Bhardwaj of Lakshmikumaran & Sridharan explain how India’s tax authorities face legal pushback over the Multilateral Instrument’s enforceability, with most favoured nation rulings now affecting its implementation

Jeklira Tampubolon and Dwipa Abimanyu Dewantara of GNV Consulting outline recent developments on import duties, the Directorate General of Taxes’ follow-up on concrete tax data, e-commerce taxation, and free trade zone regulations

Jun Au and Eddie Ahn of DLA Piper Australia analyse the Australian Taxation Office’s framework for applying the third-party debt test and debt deduction creation rules under the country’s new thin capitalisation regime

Fernando Matesanz of Spanish VAT Services examines how the opinion delivered in case C-515/24 addresses whether Spain could limit VAT deduction rights at the moment of its EU accession under the standstill clause

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse the tax authorities’ ruling on cross-border dividend withholding and the domestic capital gains exemption as applied to a Maltese trust electing corporate tax status

Jakub Warnieło and Aleksandra Bulaszewska of MDDP outline the key takeaways from a report on Polish tax trends, covering tax inspections, verification activities, tax proceedings, and the business viewpoint

Gabriel Caldiron Rezende of Machado Associados comments on the rising concerns about the tax reform transition phase, especially concerning how the old taxes will be calculated during their coexistence with the new system

Gabriel Caldiron Rezende of Machado Associados comments on the prominent role to be played by digital platforms under the new Brazilian VAT regime and the relevant compliance reporting framework

Renata Colafêmina and Rafaela Calçada da Cruz of Machado Associados discuss the test rates and ancillary obligations to be implemented from 2026, as Brazil prepares for its sweeping consumption tax changes

Dinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied

Niklas Elofsson and Vsevolod Konyshev of KPMG Sweden explore how tax functions can unlock demonstrable efficiency gains by using generative AI tools in a budget-constrained transformation landscape

Johannes Bangum, Maria Barenfeld, and Peter Nilsson of KPMG Sweden explain the main pillar two issues that arise in corporate acquisitions, including scope acceleration, top-up tax responsibilities, and earnout treatment