Expert Analysis

Indonesia is blessed with oil, gas, coal and mineral natural resources. The exploitation of energy resources (oil, gas and coal) has contributed significantly in spearheading the growth of the Indonesian economy over the past 40 years. Jul Seventa Tarigan of PB Taxand outlines the challenges taxpayers in the energy sector face and offers an example of how to utilise operations in the resource-rich country.

In transactions between related entities across jurisdictions, transfer pricing rules act to allocate profits and losses in a fair and economically justifiable manner to best reflect revenues and costs of each party to the transaction. Bruce Clements and Alan Clements of Clements Law Office discuss the factors in applying the comparability approach in the US and the UK.

Shaun MacIsaac QC, lead litigation counsel for the taxpayer in Alberta Printed Circuits, the most recent Canadian transfer pricing decision, discusses the comparable uncontrolled prices as approved by the tax court.

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