Expert Analysis

In recent years there has been a great deal of interest in corporate migrations out of the UK. But a non-UK group becoming UK headquartered is an area that has received somewhat less attention. Simon Letherman, Ansgar Simon, Don Lonczak and Iain Scoon of Shearman & Sterling in London and New York explore why US groups are attracted by inverting into Europe, and particularly the UK.

Boris Bruk and Evgeny Timofeev of Salans in Russia analyse the Bloomberg case and discover that the ruling will inspire further discussions about the framework of preparatory and auxiliary activities within the scope of the permanent establishment concept

A number of meetings have been held in recent months to discuss the future of transfer pricing in Africa. African governments, along with developed countries around the world, are proving their commitment to build up the transfer pricing systems in sub-Saharan Africa but a number of challenges stand in the way. Sophie Ashley builds a picture of transfer pricing today; how far has it come and how far does it need to go?

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