Expert Analysis

UK controlled foreign company (CFC) rules are going through a period of change. The government is trying to develop EC compliant legislation that achieves the twin objectives of minimising tax leakage through avoidance, while not being perceived as a barrier to business, so allowing the UK to remain commercially competitive, explains Ross Welland, tax partner at Haines Watts.

Canada’s Federal budget in March 2012 included changes to the transfer pricing rules. Matthew Wall, a transfer pricing expert at MDW Consulting, and Susan Robins, an international tax lawyer at Robins Tax Law, explain the benefits for the tax authority and certain concerns for taxpayers and their advisers. Though required reading for Canadians, these changes should also interest other countries particularly if they have a tax treaty with Canada or if they have issues that might be corrected by making similar changes.

Raffaele Rizzi, group general counsel at Monte dei Paschi di Siena bank explains the consequences of the Italian government’s approach to tax and how a recent ruling of the Italian Supreme Court takes this approach to the extreme.

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