Expert Analysis

Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR

Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout

Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies

João Riscado Rapoula and Hugo Leonardo of VdA analyse the new Construir Portugal scheme, outlining how targeted tax incentives are reshaping the country’s landscape for affordable housing investment and residential real estate

José Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement

Olebogeng Ramatlhodi, Africa indirect tax leader, Deloitte Africa

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

Denise Lester and Edson Uribe of Galicia Abogados address the evolution of the substance‑over‑form principle in the resolution of Mexican tax controversies and disputes.

Simón Somohano, Vicente Fuentes, Mario Roberto Coyoy González, Roberto Revel-Chion, and Juan Alberto Mendoza of Deloitte review transfer pricing (TP) developments in Mexico, Guatemala, El Salvador, Costa Rica, Nicaragua, Honduras, Panama, and Dominican Republic.

Carlos Ayub of Deloitte Brazil discusses how planned accession to the OECD will affect transfer pricing (TP) in Brazil, and also provides an update on the consequences of discontinuing the Libor rate.