Expert Analysis

While GAAR are new in China taxation, they have made great waves in the past couple of years. The controversial Circular 698 on indirect disposals will be here to stay in one form or another, but not without increasing resistance from foreign corporations and tax administrations. John Gu, Chris Xing and William Zhang of KPMG expect that the SAT may have to provide clearer guidance and explore an advance ruling system as a way to address the concerns of taxpayers.

Chinese transfer pricing rules and practices will break new ground in the coming years, finding solutions that cater to the special economic and commercial circumstances of China. Factors such as China market premiums and location savings will become more important in applying the arm’s-length principle, believe Cheng Chi, Irene Yan and Lu Chen of KPMG

“May you live in interesting times!” – a Chinese saying, so it seems. This cannot be more apt when it comes to the development of tax policy in China over the past three decades. The last 30 years have witnessed tax policy changes of such magnitude that will not be seen in China for some time to come, say Eileen Sun, David Ling and Zichong Xu of KPMG.

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