Expert Analysis

Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties

Yong Chan Lee and Eun Jin Choi of Deloitte Korea provide an update on the application of the OECD’s two-pillar solution and explain how Korean businesses can prepare for amount B’s introduction

Sanjay Kumar and Suchint Majmudar of Deloitte India provide a guide to the BEPS package and explain why streamlining the calculation of amounts A and B is integral to its successful implementation

ITR considers how insightsoftware’s Certent Disclosure Management platform addresses the various issues surrounding disclosure reporting requirements and finds it could be a powerful ally for under-pressure tax professionals

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

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

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services