Expert Analysis

Ulrich Ammelung of PwC highlights the challenges the German government faced when implementing its own bank levy and outlines how banks operating in numerous European locations with bank levies will seek opportunities to avoid double taxation while at the same time complying with the new rules.

Forthcoming changes to Indian tax law, such as the introduction of the Direct Taxes Code in 2012, and amendments to the use of limited liability partnerships for foreign direct investment, mean that taxpayers will have to rethink how they traditionally have dealt with tax planning for holding companies in India, believe Srinivasa Rao and Rajendra Nayak of Ernst & Young

Holding companies established in Cyprus enjoy many tax advantages. However, investors should be aware that they need to show management and control, and substance in Cyprus, though there are no formal definitions of what are required, say Chris Damianou and Michalis Zambartas of Eurofast Taxand

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