Expert Analysis

In the fourth in a regular series, Gautam Mehra and Nehal Sampat of PwC highlight the key challenges taxpayers face in key Indian industries. In this issue, the authors analyse the tax hurdles and opportunities in the private equity sector.

India, with its increasingly popular service industry is finding the subject of intangible assets ever more difficult to tackle. Indian specialists are involved in the UN’s transfer pricing project for developing countries with specific arguments on location savings and bargaining power, though the government has said it will not provide specific guidelines at this stage and intends to wait upon the results of the OECD’s project on the transfer pricing aspects of intangibles. Sophie Ashley looks at the issue of bargaining power in India and what it means in the debate on intangible assets.

Two recent rulings have highlighted the inconsistency of how India tackles the taxation of royalties. Gagan Kumar of Archer & Angel highlights the controversy surrounding the characterisation of payment for use of software as royalty or business profits.

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