Expert Analysis

Milind Kothari and Gaurav Shah of MZS & Associates analyse, with the aid of Indian case law, the challenges taxpayers in the shipping industry face from a cross-border tax and transfer pricing perspective.

In two separate judgments Delhi High Court ruled on the tax liability of Rolls Royce and Rolls Royce Singapore due to their operations in India. Common issue in both the matters was exposure to a permanent establishment (PE) in India and quantum of profits to be attributed to operations carried out by the PE in India. Sunil Jain of J Sagar & Associates investigates.

India’s domestic tax law follows residency-based taxation rather than source-based taxation. For an Indian tax resident, worldwide income is taxable in India. The residential status thus impacts the scope of income liable to be taxed in India. K Subramanian and S Anantha Padmanabhan of Deloitte analyse the challenges taxpayers will face once the place of effective management concept is introduced.

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