Expert Analysis

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Rahul K Mitra, Pawan Kumar, Sanjay Tolia, Amitava Sen, Suchint Majmudar and Prajwala Pai PwC Since its inception, transfer pricing (TP) has been one of the most litigated areas in the Indian tax landscape. Over the years, the TP challenges faced by taxpayers have undergone a momentous change. During the initial years of audit, the controversies arose over fundamental issues such as time period of data, choice of TP methodology, application of arm's-length range, and so on. Today, although some of these issues are attaining closure through rulings of the tax tribunal and the courts, and occasional legislative clarification, newer and more complex areas of dispute are emerging, such as the valuation of equity transfers, marketing intangibles, location savings, financial guarantees, business restructuring, high value R&D services, and others. With each passing year, the number of disputes going to the tax tribunals and the courts is mounting, and while cases are being adjudicated, the disposals have not kept pace. The recently concluded eight round of audit cycle has seen an exponential increase in the nature and quantum of TP adjustments, which would again result in considerable new litigation. One of the biggest tax disputes of recent years, the Vodafone case, was adjudicated by the Supreme Court in favour of the taxpayer. However, the relevant law was amended retrospectively to reinstate the original tax demand. Recently, the government has agreed to engage with Vodafone to enter into a non-binding conciliation to resolve the issue. Conciliation proceedings are an uncharted territory in the fast-evolving Indian tax environment and hence several stakeholders are eagerly awaiting the outcome of this development.

Joe Duffy

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

India’s Finance Act, 2026 introduces a tax framework for foreign companies using local data centres but leaves several questions unresolved, say S Vasudevan, Prachi Bharadwaj, and Loveena Manaktala of Lakshmikumaran & Sridharan

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