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Transfer Pricing
features sponsored features special focus local insights
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As we move into an era of ‘substance over form’, determining the fundamental nature of a particular instrument is key when evaluating the tax implications of selling hybrid securities
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AI is rapidly finding its way into tax advisory services. But how can AI be deployed responsibly, reliably, and in compliance with legal standards?
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Understanding India’s income tax landscape can help charities ensure compliance, optimise tax benefits, and enhance their impact, writes Raghav Bajaj of Khaitan & Co
Sponsored Features
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Sponsored by DeloitteRonnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work
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Sponsored by DeloitteSameer Nurmohamed, partner, Deloitte Legal Canada
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Sponsored by DeloitteGeorge Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)
Special Focus
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Sponsored by ATOZRomain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation
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Sponsored by YulchonSeveral 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
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Sponsored by RSM IndonesiaIchwan 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
Local Insights
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Sponsored by GNV ConsultingFabian Abi Cakra and Erviyanti Adam of GNV Consulting explain how Indonesia’s revised MSME tax regime preserves the preferential 0.5% rate while tightening eligibility criteria and introducing new anti-avoidance measures aimed at business fragmentation
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments
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Sponsored by MFA Legal & TechBárbara Miragaia of MFA Legal & Tech argues that the regime’s restrictive eligibility rules and limited relief for intra-group transactions may constrain its practical benefits