Expert Analysis

Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity

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

Lisa Zajko, indirect tax partner, Deloitte Canada

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

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

ITR and Thomson Reuters will host a webinar on June 23 at 4pm Singapore time/ 1.30pm India time/ 9am UK time to explore current and future developments impacting tax departments in India and Southeast Asia.

Federico Vincenti and Alessandro Valente of Valente Associati GEB Partners/Crowe Valente describe how cross-border mechanisms for DAC6 purposes would arise in case of a TP adjustment.

Federico Vincenti and Alessandro Valente of Valente Associati GEB Partners/Crowe Valente explain Circular 15/E which provides guidance on transfer pricing documentation in Italy.