Expert Analysis

In 2017, China's State Administration of Taxation (SAT) completed its multi-year TP legislation overhaul by issuing Announcement 6 on special tax adjustments, investigations and MAP. With a distinct anti-avoidance flavour, Announcement 6 preludes the escalation and growing complexity of TP enforcement in China. Cheng Chi, Xiaoyue Wang, Kelly Liao, Mimi Wang and Rafael Miraglia discuss.

In 2017, we saw China continue with its rollout of the BEPS changes, make proposals for new incentives for foreign investment in China, and leverage new technologies for enhanced enforcement efforts. What is more, a new vision for China's international tax policy is gradually emerging. These developments are the focus of this chapter by Chris Xing, Conrad Turley, Jennifer Weng, and Karmen Yeung.

In 2017, we saw significant new China individual income tax (IIT) enforcement trends in relation to outbound and inbound expat tax monitoring and audit, as well as equity incentive schemes. Michelle Zhou, Jason Jiang, Sheila Zhang, Angie Ho, and Murray Sarelius highlight areas to watch for in the future.

Lisa Zajko, indirect tax partner, Deloitte Canada

João Riscado Rapoula and Hugo Leonardo of VdA analyse the new Construir Portugal scheme, outlining how targeted tax incentives are reshaping the country’s landscape for affordable housing investment and residential real estate

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

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