Expert Analysis

Maik Thomas Heggmair of WTS discusses recent transfer pricing changes in Germany, including the adoption of the authorised OECD approach (AOA) into German legislation and incoming reporting changes and provides practical views on recent audit experiences.

Larissa Neumann, partner at Fenwick & West, assesses the transfer pricing landscape in the US, looking at authority attitudes and areas of focus based on recent dispute cases, and points to the need for consensus on the transfer pricing aspects of the OECD’s project to tackle base erosion and profit shifting.

Abi Briggs and Jon Tilson of Deloitte analyse recent developments regarding indirect taxation of the digital economy, taking into account OECD discussions and unilateral actions being proposed.

Join KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation

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

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