Expert Analysis

In the third of a series on intangibles, Philip de Homont and Alexander Voegele, both of NERA Frankfurt, look at brand management centres in the age of BEPS.

The envisaged ideals of ‘tax transparency’ are being proposed, and legislated, by tax administrations worldwide. This month’s Brockman brief focuses on the fact that mutual and reciprocal tax transparency with multinational entities (MNEs) remains somewhat elusive. It is now time to briefly assess some of these initiatives to fairly gauge the mutuality of such initiatives.

To start his new monthly column, Ralph Cunningham, the Hong Kong-based managing editor of International Tax Review, argues that capacity building will be critical to BEPS implementation in the Asia-Pacific region if piecemeal, unilateral measures are to be avoided.

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