Expert Analysis

Cross-border transactions and interpretation of related international tax treaties often involves controversies and issues concerning interpretation of treaty provisions and thereby leads to litigation with tax authorities. A recent judgment of the Tax Tribunal (Tribunal) in India in the case of Apollo Hospital Enterprises Limited (AHEL), has given rise to a debate regarding the interpretation of the expression “may be taxed” used in the India – Sri Lanka double taxation avoidance agreement (Treaty). Sanjay Sanghvi and Ashish Mehta, of Khaitan & Co, explore the implications.

Charlotte Rushton, managing director Asia Pacific EMEA for the tax & accounting business of Thomson Reuters, considers the challenges facing corporate tax departments in India after the recent third annual India Tax Forum.

The interaction of Poland’s transfer pricing rules and reimbursement law means the pharmaceutical industry is faced with complex compliance demands, explains Aneta Blazejewska-Gaczynska and Slawomir Buszko of Ernst & Young.

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