Expert Analysis

The European General Court (EGC) has ruled against the European Commission in the Apple case, meaning the US company does not have to repay €13 billion ($14.8 billion) in state aid benefits it received in Ireland.

Businesses are finding it difficult to deal with transfer pricing (TP) data and how to apply an arm’s-length analysis in a global economy that looked completely different just six months ago.

As countries provide incentives to attract foreign investment, the OECD may have to readdress the BEPS framework in the post-COVID future.

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