Expert Analysis

The New Zealand transfer pricing landscape has changed rapidly over the past year, explain Kim Jarrett, Kyle Finnerty and Nadia Fediaeva of KPMG. With new BEPS legislation enacted, increased tax enforcement efforts, the Inland Revenue restructuring and a new government promising an increase in spending on tax enforcement, what more could happen in a year?

The OECD’s BEPS initiative has sparked a global focus on MNEs and their transfer pricing. In recent years, writes Tony Gorgas of KPMG Australia, there has been a profound change in the ASPAC region as governments and tax administrations seek to ensure multinationals pay their fair share of tax in line with economic and value creation.

The National Assembly of Korea approved the 2017 Tax Reform Bill on December 5 2017, write Gil Won Kang, Sang Hoon Kim and Seung-Mok Baek of KPMG.

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Fernando Matesanz of Spanish VAT Services analyses a new royal decree, its implementation timetable, and the first points of tension with the EU’s VAT Directive

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

Patrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines