Expert Analysis

Eric Meier and Ariane Calloud, of Baker & McKenzie, analyse a recent case about potential permanent establishment of a French entity operating under a commissionaire arrangement with its Swiss principal.

In the past three years, the eyes of the global public have been drawn to the normally quiet world of international taxation by corporations structuring their businesses in a way that is perceived to be for no other purpose than the avoidance of paying tax. In this light, Salman Bin Hassan Al-Thani, chief financial officer and director of tax at the Qatar Financial Centre Authority, analyses the transfer pricing regimes across the Gulf Cooperation Council (GCC).

Nancy Manzano and David Deputy, of Vertex, argue that today’s tax executives must have skills that include having confidence in using the technology required to manage their company’s tax affairs effectively.

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