Expert Analysis

The interest for taxpayers in this year's Indian budget came in the proposals to amend existing legislation, such as source rules for non-residents and the tax treatment of a conversion into a limited liability partnership, reveal Vispi Patel and Rajesh Athavale of Vispi T Patel & Associates, Chartered Accountants

The OECD has released a draft implementation package that provides for a streamlined withholding tax relief process. This package is likely to be influential in terms of how countries modernise the cross-border withholding tax relief process. It may result in the holy grail of tax relief at source through standardised documentation and electronic filing to be realised.

For Canadian taxpayers and tax professionals, the general anti-avoidance rule, or GAAR, is synonymous with uncertainty. A new Supreme Court case will address some of the inconsistencies that have developed in the 18 years since the country enacted it. Erin Kelechava speaks to lawyers and the Canadian Revenue Agency about the court cases that have developed the doctrine and where they think the interpretation of GAAR is headed.

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

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance

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