Expert Analysis

Access to more company information, increasingly aggressive tax authorities, and global reform negotiations nearing their end are just some of the factors behind a heightened risk of controversy, say the tax directors and practitioners who spoke to Ralph Cunningham.

Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.

Brazil’s new treaty shows an effort to align tax law with OECD standards, say local lawyers Allan Fallet and Ariene Reis, who list some of the agreement’s key provisions.

Liliana Piedade and João Filipe Rodrigues of Cuatrecasas argue for a substantive interpretation of Portugal’s stamp duty exemption on guarantees provided by financial institutions, credit institutions, and similar entities to counterparts of an identical nature

Amit Maheshwari and Manish Garg of AKM Global provide a guide to the UAE’s nascent regulatory framework for transfer pricing and offer strategies to ensure compliance and the maintenance of proper documentation

D’Arcy Schieman, partner, indirect tax, Deloitte Canada

Shaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space

Dennitsa Dimitrova of Kambourov & Partners Tax Consulting highlights a significant tax risk in M&A transactions involving telecommunications operators and suggests what steps should be taken during the due diligence process

Vrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved

Rafał Kran and Łukasz Szatkowski of MDDP summarise a substantial revision of Poland’s real estate tax framework, with new definitions for buildings and structures, and a controversial change concerning construction equipment

Tobias Ljunggren and Jessica Silver of KPMG Sweden, who acted as counsel, analyse the implications of a court ruling clarifying that Audi’s winter testing in Sweden does not constitute a permanent establishment

Thomas Andersson and Tobias Almqvist of KPMG Sweden discuss a Supreme Administrative Court ruling affirming the right to judicial review of corresponding adjustments under tax treaties, ensuring legal remedies for double taxation disputes