Expert Analysis

The growing interest of the tax authorities in transfer pricing has increased taxpayers' recognition of the importance of transfer pricing risk assessment and management in Thailand, says Benjamas Kullakattimas of KPMG

The OECD's tax profile has rocketed this year because of the work it has done for the G20 countries on dealing with non-cooperative jurisdictions. However, many professionals believe the organisation is not inclusive enough, moves too slowly and is powerless to make countries follow its guidance. Joanna Faith finds out whether its time for a new way to set international tax standards

Transfer pricing rules are developing rapidly around the world. Nowhere more than in Asia. The increase of international trade through the region is one of the reasons why transfer pricing is firmly established as one of the biggest, if not the biggest, priorities for tax authorities there.

Sameer Nurmohamed, partner, Deloitte Legal Canada

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

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