Expert Analysis

Released only eight months ago, China's circular 698 caused much controversy as it gave the tax authorities the power to investigate transactions dating back to 2008 while requiring taxpayers to report any indirect transfers within 30 days of completion. But with many not paying attention to the circular, Jack Grocott investigates how an influential court settlement is likely to make taxpayers think twice about ignoring the circular.

The report by Mario Monti into how to complete the EU single market lends some support to the plans of Algirdas Semeta, European commissioner for tax, for a common corporate tax base. Salman Shaheen spoke to both men and other observers about the likelihood of the concept becoming reality

A 60-day wage tax exemption for foreign employees working in the Netherlands is welcome news for multinationals, say Dorine Fraai and Roxanna Windzak of Horlings, a member firm of Nexia International

Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance

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

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

Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance

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