Expert Analysis

Taxpayers with Brazilian operations should revisit their withholding positions in light of updated US guidance, writes Rafael Benevides, senior tax counsel at Meta

The OECD’s minimum tax rules will require enhanced due diligence from buyers, says Osborne Clarke partner Esther Villa

While pillar two can progress without the US, it won’t reach the same heights without American involvement, argues Renáta Bláhová, founding partner of BMB Partners Taxand

Christine Wolter, international tax lead, Deloitte Germany

Louise Kelly, head of foreign direct investment, Deloitte Ireland

A step-by-step process to manage pillar two, tax auditors’ approach to the requirements, and a summary of the data management options are among the talking points as ITR drops in on a wide-ranging webinar presented by BDO

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

António Queiroz Martins and Carolina Braga Andrade of Morais Leitão, Galvão Teles, Soares da Silva & Associados explore how Portugal’s new non-habitual resident regime is designed to attract top talent through targeted tax benefits

Pillar two will fail to achieve its aims without the participation of major economies, say João Velez de Lima, Teresa Teixeira Mota, and Francisca de Landerset of VdA

Kelvin Yuen of DLA Piper Australia summarises proposed changes to the managed investment trust regime, the deferral of a mooted foreign resident capital gains tax measure, and increased funding for the Australian Taxation Office