Expert Analysis

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Michael Bersten, Paul McCartin and Caleb Khoo PwC The tax audit and controversy landscape in Australia continues to shift and evolve against a backdrop of the federal government's commitment to addressing base erosion and profit shifting (BEPS) and to increase revenue collections. The focus on the Australian budgetary position has contributed to the Australian government introducing a number of legislative changes with the stated purpose of limiting perceived areas of potential revenue leakage. Recent changes include clarifications to Australia's general anti-avoidance and transfer pricing rules. In addition to legislative responses, the Australian government has provided additional budgetary funding to the Australian Taxation Office (ATO) to enable it to focus on areas considered to be high risk, such as cross-border financing or business restructures. In this environment, the ATO is adopting a far more evidentiary based, or litigation-ready approach to information gathering. This approach has been in response to a number of factors such as court losses which may, at least in part, be attributed to insufficient evidence collection and the recent limitations on the Commissioner's powers of discovery. This has meant that the ATO will increasingly seek to collect its evidence during the audit and objection stage rather than before litigation.

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