Expert Analysis

Originally, whenever people talked about location savings, they thought about those manufacturers that produced goods with lower than average costs to keep their competitive edge. Eunice Kuo and Nick Chen of Deloitte China explain that technology companies may need to keep an eye on this issue if costs in different operating jurisdictions allow their businesses to become more competitive.

Anne Jorritsma and Marlies Baijer of KPMG in the Netherlands argue that ambiguity in Article 8 of the OECD model treaty means that it no longer follows how the business of international maritime traffic operates.

While many countries, such as the UK, actively try to attract investment by promoting an open for business agenda epitomised by offering attractive tax benefits such as a competitive corporate income tax rate and a patent box scheme, the BRICs countries – and Brazil in particular – are managing to attract investment in spite of their unattractive and complex tax regimes. Matthew Gilleard finds out why.

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