Expert Analysis

Vitthal Dehadray of Franklin Templeton Asset Management and Rajeshree Sabnavis of BMR & Associates look at the emerging direct tax debates impacting the asset management industry in India.

The combatting of cross-border tax evasion is a priority for governments and the automatic exchange of taxpayer information between countries is now seen as fundamental to addressing it. It is out of this objective that the Common Reporting Standard (CRS), which facilitates the automatic exchange of information (AEoI) at a global level, has evolved. Mariano Giralt, Chris Mitchell and Bronwen Noble of BNY Mellon assess the impact of these initiatives on the financial services industry.

Jeffrey Owens, director of the Global Tax Policy Centre at the Vienna University of Economics and Business (WU) Institute for Austrian and International Tax Law (IAITL) and former OECD tax chief, and Nathalie Bravo, research associate at the IAITL, explore the role of a multilateral tax instrument in implementing BEPS Project measures, and analyse the treaty issues and technical challenges to be overcome.

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