Expert Analysis

Carlos Baniqued

Mark Whitehouse and Simon Wilks PwC Legal and PwC There have been a number of features of the UK tax dispute landscape over the course of the past year which are worthy of note. In the first instance, the UK's Public Accounts Committee (PAC) has taken a keen interest in tax compliance and tax avoidance. The enquiries of the PAC have included within their remit a number of important issues for large corporate groups. The PAC has summoned large corporate entities to discuss their tax affairs, including corporate groups such as Starbucks, Google and Amazon. The result of this is that this has created an environment in which many large corporate groups find their tax affairs under unusually high scrutiny.

The global economic downturn shows a greater need for tax efficient structures. There are many jurisdictions to consider for them. Michalis Zambartas of Eurofast Taxand makes the case for Cyprus, focusing on the Cypriot financial holding companies.

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