Dr. Glenn DeSouza of Dentons discusses how as fiscal pressures rise and Golden Tax IV rolls out, China is intensifying tax enforcement, placing MNEs under greater scrutiny on transfer pricing, beneficial ownership status, High and New Technology Enterprise status, and R&D super deduction claims.
The OECD has handed tax authorities a robust, treaty-sanctioned framework to attack excessive debt financing, meaning corporate tax directors must ensure every intercompany financial transaction is backed by rigorous analyses, says STI Taxand’s Christos Theophilou.
International tax scrutiny is intensifying, with disputes increasingly focused on intangibles, cross-border structures, and the correct characterization of royalties, says Baker McKenzie’s Antonio Weffer.
A proper transfer pricing policy can have big operational benefits for a company’s functions—such as cash management, supporting net operating losses, and a company’s capital structure, Cherry Bekaert’s Nelson Yates says.
An examination of the IRS’s renewed reliance on the commensurate-with-income standard and the resulting implications for transfer pricing disputes, treaty consistency, and taxpayer risk assessment.
As fast-growing companies expand across borders, failing to align IP ownership with where value is created can trigger significant tax and deal risks.
In light of the PepsiCo tax case in Australia, the South African Revenue Service may argue that certain payments made under a supply or distribution agreement are royalties subject to withholding tax.
APAs remain increasingly valuable for managing transfer pricing risk despite APMA resource constraints.
Brazil’s adoption of OECD Transfer Pricing Guidelines marks a significant shift towards global standards, presenting new challenges and opportunities for Brazilian taxpayers to align their practices with international norms and prepare for increased scrutiny.
A concise look at how governance, transparency, and structured decision‑making enable family enterprises to endure beyond three generations.
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