Expert Analysis

The Internal Revenue Service appears to be strengthening its stand on aggregating transactions and applying economic substance rationales to override related-party contracts. David Forst and Larissa Neumann of Fenwick & West discuss US developments including the IRS and Treasury Department-issued 482 Temporary Regulations.

Much lies beneath the surface of BEPS. How will BEPS affect Korean multinationals and what do MNEs need to learn? Tae Hyung Kim, partner and senior transfer pricing economist at Deloitte Korea, explains exactly what multinationals must consider and what they should fear.

Gertjan Verachtert, attorney at Sansen International Tax Lawyers and member of AIJA, analyses Belgium’s new voluntary disclosure legislation in light of recent developments in information exchange, including the ‘Panama Papers’ leak.

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead

Dave Yaros, tax principal, Deloitte Tax LLP

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

The Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

André Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny