Expert Analysis

Oliver Jaeggi and Stephan Pfenninger, of Tax Partner AG – Taxand, review how Switzerland is adapting to the latest international developments in the area of tax information exchange, including spontaneous, on request and automatic.

Bruno Bächli from Wenger & Vieli looks at the proposed measures under Switzerland’s corporate tax reform package, outlining the extent of BEPS alignment and assessing which measures are likely to be tweaked to become BEPS-compliant.

International pressure means Switzerland must harmonise its tax law to ensure the future attractiveness of the business location. Susanne Schreiber and Maxim Dolder of KPMG Switzerland provide insight on the future Swiss fiscal landscape, focusing on financing activities and the proposed notional interest deduction to maintain competitive conditions for inter-company financing activities.

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

Ratna Shakira Lie and Yoan Putra Muda of GNV Consulting explain Indonesia’s new tax guidance on insurance accounting changes, addressing the transition to PSAK 117 and its implications for income recognition and compliance

Ratna Shakira Lie and Yoan Putra Muda of GNV Consulting outline Indonesia’s relaxation of sanctions for late 2025 corporate income tax returns and payments, alongside updated rules on preliminary refunds and compliance requirements

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente 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