Expert Analysis

Authority aggression and the introduction of domestic transfer pricing regulations are creating challenges for taxpayers in India. KPMG in India’s Rohan Phatarphekar, Rajan Sachdev, Karishma Phatarphekar, Vinod Mangotra and Alpana Saksena explore whether the outlook is brighter or if the trend of increasing taxpayer difficulty is set to continue.

As challenges from various Asian tax authorities ramp up, one may think transfer pricing in Japan is no longer an issue. The focus of the Japanese tax authority might have been shifted from one transfer pricing issue to another and the types of challenges might have been changed as well; however, its emphasis on transfer pricing has never been diminished.

Bob Kee and Mei Seen Chang of KPMG in Malaysia look at how the transfer pricing landscape is changing.

India’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV

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

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

Nicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services