Expert Analysis

The OECD published a discussion draft on the future of permanent establishments (PE). Pallavi Bakhru & Nidhi Gupta of Walker, Chandiok & Co provide an insight into the Indian perspective and use examples on how the country interprets the definition of PE.

Back in January, the European Commission launched a public consultation on the double non-taxation of cross-border companies. The Commission hopes the consultation will gauge the full scale of the problem and see where the main weaknesses lie and will develop a policy response before the end of 2012. Jack Grocott speaks to Philip Kermode, Director for Direct Taxation in DG Taxation and Customs, about what he hopes the consultation will achieve and what it means for taxpayers.

The OECD’s Centre for Tax Policy and Administration (CPTA) faced an uncertain future last year when three of its high-level officials left. The candidates that have taken on the task of directing tax and transfer pricing policy have brought with them an air of calm, however, that has settled the turbulent waters at a crucial time for transfer pricing policy with their boundless enthusiasm and experience. Sophie Ashley speaks to Marlies de Ruiter, the new head of the Tax Treaties, Transfer Pricing and Financial Transactions division in her first month on the job.

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