Expert Analysis

The introduction of the UK's diverted profits tax (DPT) on April 1 2015 has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) it seemed intended to appease public anger at multinationals failing to pay their 'fair share' of tax. It has been roundly criticised for its breadth and complexity, for the speed with which it has been introduced, for the lack of public consultation and parliamentary scrutiny, and for pre-empting the multilateral response to tax avoidance of the G20/OECD BEPS Project. DLA Piper's Stephen Jones asks whether the DPT has created a cloud of uncertainty to cover the previous decade’s climate of reform favourable to global business.

As one of the founding members of the OECD and also a member of the G20 group – holding the group presidency position for 2015 – Turkey generally supports the OECD’s Action Plan to fight against base erosion and profit shifting (BEPS), explains Deloitte’s Güler Hülya Yilmaz.

Read this month's special features on Turkey and GCC

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

Federico 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

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