Expert Analysis

When Sam Maruca, the IRS’s first-ever transfer pricing director, spoke to TPWeek in October 2011, he said his aims for his time in office were to improve the organisation’s transfer pricing process. While no one could be accused of disagreeing with his goals, to improve enforcement, resources, skills and to focus on intangibles, transfer pricing practitioners think the new director could be banging his head against a brick wall because of the structure of the IRS. Two lawyers, with IRS experience, tell Sophie Ashley how Maruca’s goals translate into the marketplace.

After years of maintaining a reactionary stance, the Canada Revenue Agency (CRA) and the Canadian Department of Justice (DOJ) have collectively refocused their efforts to move earlier and more aggressively, thereby redrawing the battle lines as to the manner in which tax disputes are fought. Brandon Siegal and Chia-yi Chua of McCarthy Tétrault explain how to avoid the cross-hairs of the country’s tax officials.

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.

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