Expert Analysis

Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage

Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities

The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment

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

Anders Benktsson, Helene af Sandeberg, and Isabelle Berking of KPMG Sweden analyse a recent case that provides guidance on the Swedish withholding tax exemption applicable to non-Swedish, non-UCITS funds

Renata Colafêmina and Rafaela Calçada da Cruz of Machado Associados discuss the test rates and ancillary obligations to be implemented from 2026, as Brazil prepares for its sweeping consumption tax changes

Monika Marta Dziedzic and Paweł Wyciślik of MDDP analyse how Poland’s imposition of beneficial ownership as a condition for the application of dividend withholding tax exemptions narrows the Parent–Subsidiary Directive’s scope