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The last full compliance cycle under the Income-tax Act, 1961 before the Income-tax Act, 2025 takes effect — and the year in which TPO scrutiny of GCC margins, intra-group services and tax-holiday units has become the norm rather than the exception. A jurisdiction briefing by SBC International Tax Practice for ITR World Tax.

Amit Bhalla and Anchalee Singh of HLB Thailand explain how value chain analysis helps align transfer pricing outcomes with value creation, supporting functional analysis, documentation, and compliance

A recent publication may ease concerns about the application of the anti-abuse rule under the Dutch dividend withholding tax exemption. Jian-Cheng Ku and Roland Kleimann of DLA Piper Netherlands analyse the implications

The latest Indonesian developments include a postponement of Article 22 withholding provisions for marketplaces, Coretax-related updates, and clarification of crypto-asset reporting obligations, write Jeklira Tampubolon and Danang Syailendra of GNV Consulting

Amit Maheshwari of AKM Global examines the wider implications of the Delhi Tribunal’s decision for non-resident enterprises seeking relief under double taxation avoidance agreements

Xavier Sotillos Jaime and Inês Teixeira of Deloitte Luxembourg explore how multinational manufacturers should address industrial data in transfer pricing models as smart factories reshape value creation, investment, and risk allocation

S Vasudevan, Ravi Sawana, and Samyak Lohade of Lakshmikumaran & Sridharan examine the Delhi High Court’s EY US ruling and its implications for real-employer status, service permanent establishments, and fees for technical services

Fernando Matesanz of Spanish VAT Services analyses a judgment confirming that retaining and leasing business premises in a transfer of a going concern may trigger input VAT adjustments

I. Introduction