Expert Analysis

The financial services industry seems certain to navigate 2012 through turbulent waters with the eurozone crisis unfolding by the day, the increasingly visible hand of state regulation and bailouts, political sensitivity cumulating in the Occupy Wall Street protests, and the surging influence of the G20 emerging economies in global finance. Sam Sim and Akiko Sumikawa, two financial services transfer pricing specialists, for a leading global bank, say that taxpayers who assume the present trend will continue risk missing some forces already upon us that are shaping the future of financial services transfer pricing (FSTP).

Leon Mok, of Baker Tilly Pitcher Partners in Perth, summarises the Australian Taxation Office’s (ATO) views, the context of their evolution and also key considerations for future private equity transactions in Australia.

Taxpayers awaited the Supreme Court of Canada’s (SCC) verdict in Copthorne with anxious anticipation in December, hoping for a roadmap to help ensure they don’t fall foul of the country’s GAAR. Joe Dalton investigates what the decision means for tax planning and how taxpayers can undertake an action with no business purpose, purely to achieve a tax benefit, without this being seen as an abuse of the Income Tax Act.

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