Expert Analysis

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties

Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead

Dave Yaros, tax principal, Deloitte Tax LLP

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

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse a recent ruling of the Italian Supreme Court that clarifies the conditions for the deductibility of costs related to intercompany services

Mithilesh Reddy of Steadfast Business Consulting outlines the key transfer pricing compliance risks, pillar two impacts, and structuring priorities for multinational enterprises under the UAE’s new R&D tax credit regime

Kathya Capote Peimbert of Vertex examines how continuous transaction controls expose under‑addressed intercompany transaction risks, and outlines the approach multinationals should take to ensure consistent VAT treatment and improve audit defensibility