Expert Analysis

As India prepares itself to introduce general anti-avoidance rules in April 2012, Mukesh Butani of BMR Advisors (Taxand India) highlights the key issues within the new provisions, compares them to the other jurisdictions, and discovers that India has a long way to go in establishing best practices.

Elizabeth Bearese investigates the finer details of Canada’s tax treaty with India and explains how the treaty has become increasingly important as the two country’s seek to develop better investor relations.

Two cases from the Federal Court of Appeal in Canada have opened the door for greater scrutiny of trust arrangements. This new case law, coupled with an emboldened Canada Revenue Agency, will probably mean more pressure on taxpayers that set up these vehicles to avoid income tax. Erin Kelechava looks at the way these cases will affect tax planning and how they may be illustrative of a broader trend against tax avoidance in Canada.

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