Expert Analysis

The New Zealand transfer pricing landscape has changed rapidly over the past year, explain Kim Jarrett, Kyle Finnerty and Nadia Fediaeva of KPMG. With new BEPS legislation enacted, increased tax enforcement efforts, the Inland Revenue restructuring and a new government promising an increase in spending on tax enforcement, what more could happen in a year?

Transfer pricing rules were introduced in Sri Lanka in 2006 and became enforceable from 2008, writes Shamila Jayasekara of KPMG. The revenue authorities did not administratively enforce the rules, giving time for taxpayers to conform to requirements.

The rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writes Leonie Ferretter of KPMG. However, across the Asia Pacific region, we continue to see disparity in how TP is treated from a customs perspective.

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

Interview with Marjolijn van der Wal, partner, indirect tax, Deloitte Netherlands

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

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

Aditya Wicaksono and Reza Farhan of GNV Consulting outline new Indonesian tax provisions concerning penalty waivers, filing extensions, and compliance protections introduced under recent regulations supporting the roll-out of the Coretax system

Diana Lupu and Ana-Maria Nițu of EY Romania explain when entities subject to the global minimum tax can transition to IFRS, the key benefits and challenges, and the implications for financial reporting and compliance