Expert Analysis

A collaborative approach from taxpayers and officials has seen a growth in the popularity of unilateral advance pricing arrangements in New Zealand, explain Mark Loveday and Tanmoy Chakrabarti of Ernst & Young.

Leon Kwong Wing of KhattarWong-Taxand explains how a recent dispute from Singapore sheds light on the debate of a taxpayer’s freedom to legally arrange his affairs in such a manner that maximises his tax benefits against the natural desire of the state to collect the revenue it believes it should.

As part of a continuing worldwide trend, the US Internal Revenue Service (IRS) is ramping up its efforts to deal with the international tax issues that arise as a result of increased cross-border trade. In the last year, the IRS has realigned its resources, focused attention on strategic issues, and begun to reshape its international tax administration. Barry Shott, Richard Barrett, and Jana Lessne, of PwC US, examine the implications of the IRS competent authority changes.

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