Expert Analysis

Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements

Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions

A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland

Senior Deloitte tax practitioners offer guidance for tax leaders on the data, process, technology, and people challenges that arise when organisations go through M&A and explain how pillar two compliance raises the stakes

Marc-Oliver Beste, Florian Escherle, and Maike Moehle of Deloitte discuss how companies can manage pillar two effectively under an optimum operating model and adapt their approaches to data, talent, processes, governance, and technology

Thomas Leventis and Konstantinos Roumpis of Deloitte Greece highlight inconsistencies between Greece’s corporate tax treatment of distributed profits and international practices, and suggest a potential reform to create a clearer and more competitive 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 Răuț of EY Romania summarise the new directive on platform work and call for Romania to continue its drive towards increased tax compliance and reduced tax evasion in this area

Sandra Benedetto and Jonatan Israel of PwC Chile provide an overview of a law establishing a new legal concept that aligns taxation with ESG principles, and consider its implications for Chilean companies

S Sriram and Dinesh Kukreja of Lakshmikumaran and Sridharan examine the tax consequences of foreign business reorganisations in India, including indirect transfer rules, statutory exemptions, and treaty benefits for multinational companies