Expert Analysis

One of the few transfer pricing cases to go to trial in the US in the last decade won an Americas Tax Award from International Tax Review for Symantec, the taxpayer at the centre of the litigation.

On September 15 2011, the Dutch government published its 2012 budget proposals. The proposals include further limitations on the tax deduction of interest payments by acquisition holding companies and the introduction of a revised exemption for foreign branch profits. In addition, anti-abuse provisions are proposed in connection with the taxation of non-Dutch resident corporate shareholders in Dutch companies and the levy of dividend withholding tax on certain profit distributions made by Dutch co-operatives. René van Eldonk and Steven den Boer of Simmons & Simmons analyse the proposals.

Providing a contract of insurance in the UK without the necessary permission or exemption is a criminal offence and renders the contracts unenforceable by the provider. Robert Viney of Davies Arnold Cooper offer some advice to ensure providers of avoidance schemes are on the right side of the line.

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