Expert Analysis

The valuation of intellectual property (IP) for transfer pricing purposes has recently received a lot of attention from the US government. Philippe Penelle and Lawrence Shanda take taxpayers through the specifics of IP valuation, payment forms and discount rates, in light of the IRS’s new focus on migrated IP.

Shanto Ghosh, John Wells, and Todd Wolosoff discuss the recent stages in the OECD’s project into the transfer pricing aspects of intangibles and comment on the inconsistencies in the draft and what these could mean for taxpayers.

The unrelenting pursuit of profit by enterprises is an exalted virtue of modern capitalism. Most start-ups operate in countries where corporate taxes can take up a significant portion of their ultimate profits or valuations. Aydin Hayri and James Gannon explain why a start-up ignores corporate taxation at its own peril.

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