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Expert Analysis

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Transfer Pricing
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
November 20, 2025
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  • New data and technology-driven, risk-oriented, tax administration and enforcement approaches by the Chinese tax authorities are compelling taxpayers to up their game. Taxpayers are developing enhanced internal tax risk controls and IT, and engaging with the tax authorities in a collaborative manner. Tracy Zhang, Wei Fang, Anthony Chau, Lilly Li, discuss the latest trends and changes.
  • Ayesha Lau, Darren Bowdern, Michael Olesnicky, John Timpany and Curtis Ng discuss Hong Kong’s BEPS-related changes after the territory issued a consultation paper to codify and strengthen TP regulations, as well as joining the Multilateral Instrument (MLI). The Hong Kong government is also increasingly using tax policy to encourage economic development.
  • In 2017, the Taiwan government proposed imposing VAT on foreign enterprises providing e-commerce services to Taiwan individuals, expanding the Taiwan corporate income tax (CIT) nexus rule, and making personal income tax changes. It is also looking at abolishing and replacing the corporate-shareholder imputation tax system. Stephen Hsu, Hazel Chen, Ellen Ting and Betty Lee elaborate.

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