Expert Analysis

The roll out of enhanced tax exemptions for offshore private equity funds, the improvement of intellectual property and treasury centre incentives, the expansion of Hong Kong’s tax treaty network and the putting in place of arrangements for automatic exchanges of information are the focus areas of this article by Ayesha Macpherson Lau, Darren Bowdern, Michael Olesnicky, and Curtis Ng

The G20/OECD BEPS proposals are being rolled out into Chinese tax law and practice, with implications for multinational enterprises (MNEs) doing business in China. The focus of this chapter by Chris Xing, William Zhang, Lilly Li and Conrad Turley is recent and upcoming regulations and guidance which are positioning China at the forefront of global BEPS implementation

The drivers and nature of increased IIT enforcement efforts by the Chinese tax authorities are considered in this chapter by Michelle Zhou, Chris Ho, Vincent Pang and Angie Ho

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

The key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault

The Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan

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