Expert Analysis

Julie Carbiener

Intra-Asian trade represents nearly two thirds of total Asian trade as of 2016, according to the Asian Development Bank. This is in stark contrast to the past two years where the large markets of the US and the European Union dominated the majority of Asian exports. As with the rest of the world, however, trade volumes in Asia have grown at a slower rate over the past two years, although the growth in trade amongst regional trading partners has generally outpaced the overall growth in trade. What does all this mean? Intra-Asian trade will continue to increase its share of total Asian trade flows, making the need for a regional trade pact imperative as global supply chains consolidate in Asia Pacific. With the Trans-Pacific Partnership (TPP) nearly, though not entirely, eliminated as a possibility the region looks to the China-led Regional Comprehensive Economic Partnership Agreement (RCEP) to fill the gap. In order to achieve the promise of fully integrated Asia Pacific trade, however, some argue that the RCEP will need to be more ambitious and address more than simply tariff rate reductions.

Christian Buergler

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

Stephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences

André Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny

Samuel Fernandes de Almeida and Ana Rita Carvalho of MFA Legal & Tech explain how a Portuguese binding ruling fuels the emerging dispute with Spain over non-habitual tax residents