Expert Analysis

Urs Kapalle, head of tax and fiscal policy at the Swiss Bankers Association (SBA) in Basel, and Dominic Gubler, tax counsel at the SBA, look at tax transparency and information sharing initiatives involving Switzerland, assessing FATCA and automatic exchange of information from the Swiss perspective and highlighting the past, present and future activities relating to implementation of the country’s tax transparency strategy.

With continuing signs of a more business-friendly attitude from the Indian government, mergers and acquisitions (M&A) activity is picking up once more. Sanjay Sanghvi and Vinita Krishnan of Khaitan & Co analyse the role of ‘tax cursors’ in the successful completion of a transaction.

Guillermo Teijeiro, of Teijeiro & Ballone Abogados, analyses voluntary disclosure programmes available across Latin America, assessing whether such programmes represent a win-win outcome for all involved.

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