Expert Analysis

Tax evasion in India is an intensely politicised matter, and disputes such as that surrounding Hyundai Motor India Limited, which faces evasion charges amounting to Rs266 crore ($59 million), indicate that the issue is still as rife as ever. But recent initiatives such as the revised India-Switzerland tax treaty could mark the first significant steps towards reining the problem in. Matthew Gilleard investigates.

The recently released concept paper on taxation of services based on the Ministry of Finance’s negative list concept has evoked mixed reactions from industry. This is an important development and while industry has lauded the move towards a comprehensive and simplified service tax regime, Harishanker Subramaniam of Ernst & Young explains that there are strong views on the timing of its implementation and its impact on certain sectors.

Vispi Patel and Rajesh Athavale of Vispi T Patel & Associates explain how recent judicial rulings throw light on different aspects of transfer pricing and offer guidelines to taxpayers on the way to mitigate transfer pricing risk in India.

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