Expert Analysis

The drivers and nature of increased IIT enforcement efforts by the Chinese tax authorities are considered in this chapter by Michelle Zhou, Chris Ho, Vincent Pang and Angie Ho

The highly significant changes to transfer pricing guidance planned for under the SAT’s public discussion draft on ‘Special Tax Adjustments’ (yet to be finalised at the time of writing), and the impact of these changes in the light of evolving Chinese transfer pricing enforcement practice is the focus of this chapter by Chi Cheng, John Kondos, Simon Liu, and Kelly Liao

The Year of the Sheep, now drawing to a close, has been a signature year both economically and fiscally for China. China had surpassed the US as the world's largest economy, in purchasing power parity terms, in 2014. It had similarly become the world's largest recipient of foreign direct investment (FDI), also overtaking the US, in that year. Remarkably, while China takes the top position as a recipient of FDI, Chinese outbound direct investment (ODI) is projected to overtake FDI for 2015 as a whole, making China a net exporter of capital. Projections further show China overtaking the US in ODI terms to become the world's premier source of ODI within a short few years. There is no doubt that China is becoming ever more central to the global economic order. Nevertheless, as the Chinese government seeks to shift her economy from reliance on investments, exports and heavy industries to a more consumption and service sector-driven model, the pace of economic expansion in China will ease off before picking up again. In the meantime, the government will go to every length to safeguard her tax revenues.

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 key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault

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