Expert Analysis

The 2012 International Tax Review Asia Tax Forum, held in Singapore, once again attracted scores of tax professionals from throughout the Asia-Pacific region and beyond. While transfer pricing was high on the agenda, it was not the only concern and other panels included: keeping in step with Chinese rules changes; establishing trust between officials and taxpayers; dealing with developing tax systems; the Indian reform; cross-border issues; dispute resolution; improving effectiveness in the tax department through technology; and indirect tax.

Napoleão Dagnese head of international tax at OC Oerlikon, a high-tech industrial company, provides a critical analysis of the changes to the Brazilian transfer pricing regime, from the taxpayers’ perspective.

Conor Hurley and Jonathan Sheehan of Arthur Cox explain why Ireland is the ideal location for investment and explain why the country’s tax regime makes it the best location for structuring an acquisition, whether Irish or international.

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