Corporate tax
October 2025 | SPECIAL REPORT: CORPORATE TAX
Financier Worldwide Magazine
October 2025 Issue
Q&A: Futureproofing the tax function
The tax function will evolve into a strategic business advisory role powered by advanced technology. AI and automation will handle routine tasks, while professionals focus on complex analysis, strategic planning and business consultation. FW discusses futureproofing the tax function with Romain Tiffon at ATOZ Tax Advisers.
Effective management of tax disputes for multinational enterprises
Brown Rudnick LLP The globalisation of tax disputes is no longer anticipated – it is here. With unprecedented levels of information exchange, deeper cooperation between tax authorities and a sustained political drive for enforcement, multinational enterprises cannot afford a reactive stance.
Managing a transfer pricing dispute: global perspectives
Gowling WLG Transfer pricing disputes are inherently complex and strategic. Whether through administrative appeals, mutual agreement procedure or litigation, taxpayers must carefully assess procedural, financial and jurisdictional factors before choosing a path forward.
The US Model Income Tax Convention: emerging challenges and treaty evolution
Caplin & Drysdale The US Model provides for mandatory binding arbitration in the event the competent authorities cannot reach agreement on the arm’s length outcome in a mutual agreement procedure or advance pricing agreement.
Implications of HMRC’s desire to ‘shrink the tax gap’
Simmons & Simmons The UK government is in need of a magic money tree. When UK governments feel that sort of pressure, they tend to promise to reduce the ‘tax gap’ – the difference between the amount of tax that the UK’s tax authority HMRC believes it should be able to collect, and the amount it actually collects.
Lessons from Australia’s ‘weaponisation’ of its income tax general anti-avoidance rules
Johnson Winter Slattery There is little doubt that Australia is well ‘advanced’ in the administration of its income tax general anti-avoidance rules. For tax residents in a jurisdiction other than Australia, it may be worthwhile reflecting on their jurisdiction’s journey to ‘weaponising’ its GAAR and whether there are lessons that may be learnt and applied from the Australian experience.
Latest developments in South Africa in the context of tax controversy
Cliffe Dekker Hofmeyr Statistics underscore the South African Revenue Service’s emphasis on collecting taxes in circumstances where the dispute resolution mechanism is overflowing.
Q&A: Tax considerations in cross-border M&A amid ongoing market volatility
Tax implications for cross-border M&A will continue to evolve toward an increased demand for tax reporting and data collection. FW discusses tax considerations in cross-border M&A amid ongoing market volatility with Irene Reoyo, Sergi Lemus, Dany Teillant and Angelica Tsakiridis at Deloitte.
CONTRIBUTORS
ATOZ Tax Advisers
Brown Rudnick LLP
Caplin & Drysdale
Cliffe Dekker Hofmeyr
Deloitte
Gowling WLG
Johnson Winter Slattery
Simmons & Simmons