Expert Analysis

Confusion over the interpretation of India’s 5% allowable variation in the difference between the actual price of transactions and the arm’s-length price led to the government amending the rule in this year’s budget, but, as Salman Shaheen finds out, the changes have only created further confusion and there is still no sign of long-awaited safe harbour rules

The tax authorities in the US have designed regulations to encourage employees to come forward with information about a corporation’s aggressive tax planning schemes, with promises of hefty rewards for tips that leads to the recovery of money. Erin Kelechava finds that these regulations and other new IRS initiatives, such as Schedule UTP, may complicate matters for corporate tax departments by requiring that they increase transparency, institute internal controls, and scrutinise their tax positions.

Jock McCormack and Anshu Maharaj of DLA Phillips Fox discuss recent developments in Australia that will impact managed investment funds, controlled foreign companies, foreign accumulation funds, collective investment vehicles, trusts and the disclosure of uncertain tax positions.

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