Expert Analysis

The IRS is unhappy with multinationals exploiting cross-border differences in treatment of debt and equity for tax gains and is throwing more resources into preventing it. But Hewlett Packard, Scottish Power and PepsiCo were all challenged in the US Tax Court over debt-equity issues last year and two of them emerged victorious. Joe Dalton explains why such structures are still a valid and beneficial option for taxpayers and how to prepare your case if the IRS comes calling.

There has been a significant rise in controversy around the world in recent years centred on the topic of the beneficial owner test which appears in the dividends, interest and royalties articles of most double tax treaties. Richard Collier, of PwC, explores the work of the OECD in this area to date and what the future holds, calling for greater clarity on the concept.

After a couple of years of work in preparing the tax reform Bill and several months of discussion and debate in the Colombian Congress, the government approved Law No 1607 on December 26 2012. With 198 articles, the law seeks to confront tax evasion in Colombia, as one of its main objectives. Diego González-Béndiksen De Zaldívar, head of DIAN’s (Colombia’s National Tax and Customs Direction) International Audit Unit, and Andrea Medina Rojas, an international auditor in the unit, describe the law’s process and what it will mean for taxpayers.

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

India’s Finance Act, 2026 introduces a tax framework for foreign companies using local data centres but leaves several questions unresolved, say S Vasudevan, Prachi Bharadwaj, and Loveena Manaktala of Lakshmikumaran & Sridharan

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