Expert Analysis

A key lesson of the global volume recession in 2008 and 2009 is that transfer pricing benchmarking and comparability studies need to be revised to take account of changing economic conditions, explain Seen Meng Chew and Harlow Higinbotham of NERA Economic Consulting

French groups have more flexibility to decide how to divide the tax burden among its members after two Supreme Court decisions. However, the rulings could also change how M&A take place when it involves entities that have suffered losses, explain Renaud Jouffroy and Jean Sayag of Landwell et Associés

As the economic turmoil recedes, the demand for Islamic financing is increasing again. It has led some key jurisdictions to reexamine their tax rules to ensure that such transactions are possible, explains Kevin Conway, John Taylor and Markus Krismanek of King & Spalding

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

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

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