Expert Analysis

Read this month's special features on Brazil, Germany, India and North America.

Whatever form and acronym it takes (a similar, though narrower, examination was conducted in the 1990s under the banner of harmful tax competition (HTC)), base erosion and profit shifting (BEPS) has been an underlying theme in international taxation for years. But only recently has it risen to the top of the international taxation and political agendas, no doubt accelerated by the tax planning opportunities opened up by the globalisation and mobility of commerce. With Australia poised to take on the presidency of the G20, David Bradbury, Assistant Treasurer until the September election, and a driving force behind much of Australia’s work on tackling BEPS, analyses the impact the country has had on this global debate, looking at the policies his government implemented to get to this stage, and how the new government can take things forward.

Donato Raponi, head of the European Commission’s VAT Unit, discusses the new VAT rules applying from 2015 to telecommunications, broadcasting and electronic services and the publication of Commission guidelines on the practical functioning of the mini one-stop shop.

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