Expert Analysis

The Argentine tax authorities have become more aggressive in recent years, particularly in transfer pricing matters, and have not been afraid to take legal action against taxpayers, reports Juan Manuel Soria Acuña of MCRLex

Tax Controversy Leaders is a guide to the leading tax dispute resolution lawyers and advisers in the world. In addition to highlighting tax professionals, the guide also includes litigators and barristers who may not practise tax on a day to day basis.

The Canada Revenue Agency (CRA) audits large corporate taxpayers on a regular basis. To improve efficiencies and cash recoveries, CRA is moving to a risk-based assessment approach to auditing such taxpayers. Over the next five years, corporate taxpayers will be assessed as low, medium and high risk, based on a series of factors. The frequency and intensity of the audit processes will vary directly with the risk ascribed to the particular taxpayer. Consequently, large corporations which now face consistent audit scrutiny on domestic and cross-border tax issues may find that CRA audit work abates or becomes more focused on specific areas in which significant tax liabilities may arise. Two areas of continuing review involve transfer pricing and aggressive tax planning. CRA regards the latter term as one referring to arrangements which comply with the letter but not the spirit of the statutory provisions that give rise to tax benefits.

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