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Direct Tax
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The conversion to international financial reporting standards (IFRS) is anticipated by many global companies, and many have already implemented, or are in the process of implementing, the new standards for statutory purposes. As companies continue to adopt the new principles, their tax departments and transfer pricing practitioners will be expected to maintain seamless continuity in demonstrating that intercompany transactions are priced in accordance with the arm’s-length principle (or are priced as if the transactions had taken place between third parties). For many companies, this has started to cause transfer pricing concerns. Kristine Riisberg, Deborah Keisner, and Todd Wolosoff, of Deloitte Tax, New York, explain why.
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International Tax Review and TPWeek hosted the 12th annual Global Transfer Pricing Forum in Paris in September.
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The financial transaction tax (FTT) is set to be introduced by 11 EU member states. Richard Murphy of Tax Research looks at the case for an FTT, how it would work in practice and why, contrary to other anti-poverty campaigners, he believes it should not be used to raise revenue for developing countries, but to constrain out of control banking.
Sponsored Features
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Sponsored by KNAV IndiaIndia’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
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Sponsored by insightsoftwareJoin 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
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Sponsored by DeloitteJess 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
Special Focus
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Sponsored by YulchonSeveral 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
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Sponsored by RSM IndonesiaIchwan 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
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Sponsored by Tax PartnerMonika 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
Local Insights
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Sponsored by Lakshmikumaran & SridharanIndia’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
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Sponsored by Pérez-LlorcaNicolle 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
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Sponsored by PwC ChileNatalia 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