lead
Transfer Pricing
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
May 7, 2026
features sponsored features special focus local insights
-
-
As governments around the world assess the best way to attract – and tax – R&D and intellectual property investment, Giulia Cipollini and Bianca Macrina of Withers in Milan look at the incentives taxpayers can avail in Italy, tracking the nuances of the Italian Patent Box regime from introduction to operation. -
Charles Yorke and David Stainer, of Allen & Overy, review the latest UK Government proposals on improving compliance by large corporate taxpayers, including a ‘voluntary’ code of practice likely to give rise to fears of ‘mission creep’.
Sponsored Features
-
Sponsored by DeloitteJess 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
-
Sponsored by DeloitteDeloitte 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
-
Sponsored by DeloitteDave Yaros, tax principal, Deloitte Tax LLP
Special Focus
-
Sponsored by YulchonSeveral 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
-
Sponsored by RSM IndonesiaIchwan 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
-
Sponsored by Tax PartnerMonika 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
Local Insights
-
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications
-
Sponsored by McCarthy TétraultThe 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
-
Sponsored by Lakshmikumaran & SridharanThe 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
