Expert Analysis

Developing countries often impose withholding tax on payments for certain offshore services. Companies should be aware of where in the world this occurs and the potential protection under tax treaties so they can plan accordingly, says Konstantin Korobchenko of EY and the University of Leiden.

Vijay Krishnamurthy, CFO, company secretary and legal head at SmartPlay Technologies India, looks at the recently notified general anti-avoidance rules (GAAR) in India, analysing whether certain inconsistencies remain and whether the recommendations of the specialist Parthasarathi Shome-led committee should have been adopted in full.

The US Supreme Court heard the oral arguments in the Woods dispute last month, which deals with whether valuation misstatement penalties are applicable in tax shelter cases. Professor David Shakow, of the University of Pennsylvania Law School and counsel at Chamberlain, Hrdlicka, White, Williams & Aughtry, who filed an amicus brief against the government in the case, explains why taxpayers hope the court’s judgment will help clarify two controversial areas of US tax law.

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