Expert Analysis

Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.

Caroline Setliffe and Ben Shem-Tov of Eversheds Sutherland give an overview of the US transfer pricing penalty regime and UK diverted profits tax considerations for multinational companies.

In an exclusive interview with ITR, Deborah O’Neill says the PwC Australia tax leaks scandal has revealed an industry rife with malpractice and that she’s not going to stand for it.

Tax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Gabriel Caldiron Rezende of Machado Associados examines the debate concerning the inclusion of CBS and IBS in the ICMS taxable base and considers whether increased litigation may be on the horizon

Raghav Rajeev and Nimrah Ali of Lakshmikumaran & Sridharan analyse the approaches taken by taxpayers and Indian judicial bodies on contested tax payments under the country’s goods and services tax law

Bernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address