Expert Analysis

The OECD has released a draft implementation package that provides for a streamlined withholding tax relief process. This package is likely to be influential in terms of how countries modernise the cross-border withholding tax relief process. It may result in the holy grail of tax relief at source through standardised documentation and electronic filing to be realised.

Enhanced tax information exchange and greater offshore compliance was the biggest outcome of the G20 summit of world leaders last April in London. The subsequent 12 months saw increased tax cooperation between governments and hundreds of international information exchange agreements signed. Jack Grocott discovers what all this means for multinational companies.

The interest for taxpayers in this year's Indian budget came in the proposals to amend existing legislation, such as source rules for non-residents and the tax treatment of a conversion into a limited liability partnership, reveal Vispi Patel and Rajesh Athavale of Vispi T Patel & Associates, Chartered Accountants

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