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

Interview with Bernard Mofokeng, head of tax controversy (South Africa), Deloitte Africa tax and legal

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

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

Mikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters

With South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy

Edouard Authamayou and Christelle Larcher of Deloitte Luxembourg explain how several recent rulings have clarified the Administrative Court’s stance on the application of ex officio taxation in the grand duchy

Jian-Cheng Ku, Xander Stubenrouch, and Isa Weijman of DLA Piper Netherlands explain a recent ruling by the Amsterdam Court of Appeal regarding dividend stripping, and its broader meaning in an evolving tax landscape

Multinational groups may need to reassess their strategies in the wake of the US president’s sweeping tariff changes. Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente outline ways to mitigate the impact