Expert Analysis

The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief

The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals

User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley

Join Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations

Join ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court

Interview with Candy Ye Tang, tax and business advisory leader, Deloitte China

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Mark Martin and Thomas Bettge of KPMG in the US discuss the inclusion of updates to the US Internal Revenue Service’s (IRS) mutual agreement procedure (MAP) and advance pricing agreement (APA) revenue procedures in its priority guidance plan, and consider how successor guidance could further improve the MAP and APA programmes.

Jeklira Tampubolon and Aditya Nugroho of GNV Consulting summarise the recent regulatory developments concerning Indonesian exports, with a particular eye on palm oil and its derivatives.

Oscar Lopez Velarde, Juan Jose Paullada and Alonso Miranda Barceló of Ritch Mueller explain why some Mexican entities will need to reassess the structuring and viability of financing their energy projects following the modification of the thin capitalisation rules in Mexico.