Expert Analysis

A booming economy and an increasing focus on investment is forcing the Indian tax authorities to step up scrutiny on all cross border trade. Rohan Phatarphekar and Hardev Singh of KPMG outline how transfer pricing will be the hot topic over the coming year.

Taxpayers will be heartened by the decision of the French Supreme Tax Court in the Zimmer case on the existence of a permanent establishment. Renaud Jouffroy and Marie-Laure Hublot of Landwell et Associes examine the verdict, pointing out that it left some questions unanswered

The Anti-abuse Rule has made it difficult to avoid the payment of transfer tax when buying real estate assets in Spain. However, investors who have paid the tax may be entitled to a refund if the rule is found not to comply with European law, explains Carlos Duran Haeussler of Uría Menéndez

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