Expert Analysis

As part of its continuing efforts to improve international operations, the US Internal Revenue Service (IRS) recently announced the reorganisation of its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes into a combined advance pricing and mutual agreement (APMA) programme. Kerwin Chung and Todd Wolosoff of Deloitte explain what the reorganisation, and its potential impact on taxpayers seeking APAs, will mean.

Nicola Saccardo of NCTM explains how different types of income from financial assets will be taxed in Italy.

Japan is rolling out the red carpet for foreign investors in a bid to jumpstart its economy, which is struggling to recover from severe economic conditions triggered by the global financial crisis, the catastrophic earthquake and tsunami, and a strong yen. Hitoshi Takano, Jonathan Stuart-Smith and Linda Ng of Deloitte explain how newly created special zones and other tax incentives for companies may mean they consider relocating.

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