Expert Analysis

Italian Supreme Court decisions on the abuse of right in 2008 and this year looked for harmonisation between business freedom and protection of the fundamental principles of the State legal system, reveals Maricla Pennesi of DLA Piper

Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HMRC tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority and part of working party 6, offers taxpayers an insight into how transfer pricing cases are selected in the UK and talks about the future of transfer pricing.

In a recession transfer pricing risk is intensified as tax authorities scrutinise intercompany payments rigorously in an attempt to recover cash. Joanna Faith finds out what tax departments can do to improve their positions and avoid aggressive auditing in the downturn.

Sameer Nurmohamed, partner, Deloitte Legal Canada

George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)

Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance