Expert Analysis

Many years ago, I was responsible for a tax group that reported to a regional group services organisation and not to the global head of tax. A new manager, with no experience of tax, had just taken over responsibility for group services and was looking to find out what each of his new teams actually did and for simple performance metrics.

Keith Brockman looks at how to prevent and resolve disputes just as the international tax system is changing.

Opportunities to come to a resolution with the tax authorities are generally better the earlier they present themselves in the life-cycle of a tax dispute, says Sandy Markwick, head of the Tax Director Network (TDN) at Winmark.

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

Jeklira Tampubolon and Julius Wahyu Daryono of GNV Consulting also summarise regulations concerning customs and excise bookkeeping and an import duty exemption for goods used in government projects financed by foreign loans and/or grants

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