Expert Analysis

Arvind Singal and Nitin Kapoor of RBS Services India explain the difficulties for businesses caught by India’s equalisation levy and how foreign companies outside the e-commerce sector may fall under the scope of the expanded tax.

The Apple case is just one of many disputes between the European Commission and multinational companies that revolve around fundamental questions about transfer pricing (TP), in particular the arm’s-length principle (ALP).

The European Commission has defended its controversial 2016 Apple state aid decision after losing the case at the European General Court (EGC), but some lawyers are not anticipating an appeal.

Cecilia Margarita Montaño Hernández, partner, indirect tax, Deloitte S-LATAM

Mahesh Jaising, indirect tax leader, Deloitte India, and indirect tax chief growth officer, Global Deloitte

A spate of reforms has added to the growing appeal of Portuguese alternative investment funds. José Maria Cabral Sacadura and Francisco Soares Machado of Cuatrecasas explain the various vehicles available and the applicable tax framework

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

Claudia Sofianu and Dan Răut of EY Romania discuss the growing challenges of cross-border teleworking, highlighting the complexities of taxation rights and the need for clearer and more unified EU regulations

Endy Arya Yoga and Nanda Atsatalada of GNV Consulting summarise legislative updates concerning corporate income tax reduction facilities, bad debt expense deductions from gross income, and implementation of the Core Tax Administration System

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss a recent decision by the Brazilian Supreme Court that ensures proportionality in tax penalties and strengthens legal protections for businesses