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.

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

Join ITR for a free webinar on September 30 as insightsoftware, with guest speakers from Alvarez and Marsal Tax, explores how evolving technology is reshaping talent strategies and how organisations can close a skills gap

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Silke Lappe and Karen Smolka of Deloitte Germany examine transfer pricing challenges and governance considerations for cybersecurity and generative AI services, highlighting how emerging technologies are reshaping value chains, compliance demands, and multinational tax approaches

Marco Heuer and Nik Nolden of Deloitte Germany examine how shifts in tariffs, foreign exchange and interest rates, and geopolitical tensions impact multinational groups’ transfer pricing strategies

Stephan Habisch and Florence Müller of Deloitte Germany examine how tariffs disrupt transfer pricing, forcing multinationals to reassess supply chains, manage compliance risks, and explore strategic restructuring to balance challenges with emerging opportunities

Teresa Teixeira Mota and André Vilaça Ferreira of VdA discuss the implications of a binding decision regarding the application of double tax treaty provisions to payments made by Portuguese companies to foreign partnerships

Kelvin Yuen and Eddie Ahn of DLA Piper Australia review draft Practical Compliance Guideline 2025/D4, outlining its low-risk zones for cross-border software payments and implications following the recent landmark PepsiCo High Court decision

Edouard Authamayou of Deloitte Luxembourg examines an Administrative Court ruling confirming that tax authorities have full discretion under Section 100a of the General Tax Law to review assessments, with procedural deadlines of critical importance