Expert Analysis

Filipe Romão and António Castro Caldas of Uria Menéndez – Proença de Carvalho discuss the practical implication of amendments to Portugal’s participation exemption regime and discover that the changes leave a lot to be desired when compared to its European counterparts.

Another year of transfer pricing development brings hope, for taxpayers and their advisers, that processes will be streamlined, guidelines will provide clarity and policy reform will allow for better interpretation. A new year allows for contemplation about the direction governments and tax authorities should take. Sophie Ashley reports on the expectations of global and regional advances.

BP Solar’s sale of a number of PV plants in Italy to a leading insurance company gave rise to a complex tax structuring case, which was also affected by a new interpretation by Italy’s tax authorities, explains Federico Trutalli of NCTM, who advised the seller during the transaction.

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