Expert Analysis

In Belgium a common tax planning technique is to convert taxable sale of assets into tax exempt sale of shares through tax neutral reorganisations such as demergers. But with the authorities scrutinising such reorganisations and applying anti-abuse law provisions, Astrid Pieron of Mayer Brown offers advice on how taxpayers can avoid the attention of officials.

The Department of Finance recently released proposed amendments to Canada’s foreign affiliate regime including rules dealing with so-called upstream loans. Bruce Sinclair and Kirsten Kjellander of Blake, Cassels & Graydon explore implications of these proposals for multinational enterprises involved in the natural resource industry.

In transactions between related entities across jurisdictions, transfer pricing rules act to allocate profits and losses in a fair and economically justifiable manner to best reflect revenues and costs of each party to the transaction. Bruce Clements and Alan Clements of Clements Law Office discuss the factors in applying the comparability approach in the US and the UK.

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