Expert Analysis

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.

With seemingly continuous corporate tax law reforms, Andreas Staubli and Remo Küttel of PricewaterhouseCoopers outline the future for Switzerland's tax system and what the proposed changes mean for attracting inward investment

The new VAT regime and other developments in its tax law make Switzerland even more attractive as location for holding companies and international group companies with financing activities there, believe Markus Prinzen, Mathias Bopp, Marcel Angehrn and Timo Haack of PricewaterhouseCoopers

Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance

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

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

Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test

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