Expert Analysis

The last couple of years have witnessed a radical change in the Indian tax controversy landscape. Issues, which one would have thought are beyond the horizon a few years back, now occupy the most prominent space in the Indian tax controversy expanse. One such recent emergence is that of taxation of offshore transfer of shares of an overseas company. Arun Chhabra & Nidhi Gupta of Walker, Chandiok & Co investigate.

The Indian government is rumoured to have changed tack on its structuring of the upcoming advance pricing arrangement (APA) programme. Taxpayers expected a unilateral APA to be incorporated into the Direct Taxes Code in 2012 but officials could be bending to arguments from lobbyists that this way of establishing certainty about transfer pricing would be arbitrary. Sophie Ashley takes a fresh look at the APA process and considers the pros and cons to unilateral and bilateral APAs.

Daksha Baxi and Surajkumar Shetty of Khaitan & Co analyse a decision from the Authority for Advance Rulings which ruled that the cross-charge of salary cost under a secondment arrangement represent fees for included services and so warrants withholding tax.

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