Expert Analysis

A new version of a Bill to combat offshore tax evasion has made its way into the Tax Extenders Act that has been passed by the US House of Representatives. Changes to the Bill have produced some clarity, but controversies persist as Erin Kelechava discovered when she spoke with tax professionals about FATCA'S implications.

Diane Hay, formerly of the UK tax authorities, worked on the key provisions of what became the UK's new rules on the taxation of overseas income. In an extract from a new book she describes the final stage of the project

The French government has abolished the unpopular taxe professionnelle. David Stevenson finds out why it has done so and the prospects for the tax's replacement.

George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)

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

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