Expert Analysis

A spate of recent examples indicates that inversion transactions are as popular as they have ever been, with Pfizer’s attempted deal with AstraZeneca highlighting that companies in the pharmaceuticals industry are increasingly using the inversion option. William Fry Tax Advisors, the Irish member firm of Taxand, look at why this is, and analyse why Ireland is proving to be the location of choice for newly-formed companies post-inversion.

Taxation of cross-border structures and new exchange of information measures are two reasons why Russia’s new de-offshoring policy will have an impact on foreign as well as domestic groups, explain Estella Dzhantukhanova, Elena Solovyova, Alexander Krylov and Kateryna Grynova of Deloitte, Russia.

To say that the European financial transaction tax (FTT) has been controversial would be an understatement. From its inception in September 2011, the EU proposal has been met with vitriol from some in the financial sector, who argue that the tax will pilfer pensions and wreak havoc on the European economy, while others have championed it as the solution to the eurozone crisis, labelling it the ‘Robin Hood Tax’. It also has the added advantage of appeasing a politically disillusioned electorate by promising to land a decisive blow to bankers, who in the public’s view caused the mess in the first place. Aaran Fronda dissects this divisive tax.

India’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV

Join KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation

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

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

Nicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services