Expert Analysis

Taxpayers must prepare for an increasing number of difficult questions from the tax authorities over the coming decade. ITR reviews a few of the biggest upcoming TP cases for tax professionals to keep an eye on in 2020.

Tax departments need to work closely with their HR teams to ensure compliance with the UK’s IR35 rules. Mala Kapacee, director of London Tax Network, explains how companies should get ready for the amendments to the anti-avoidance measure.

Are countries implementing the Multilateral Instrument for the sake of it, or will it bring about real change? Karnik Gulati questions the real consequences of the MLI and suggests how companies should prepare.

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