Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector

As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands

As joint audits, data sharing and pillar two reshape tax controversy, multinational groups can no longer afford to manage disputes one jurisdiction at a time

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

Join insightsoftware on September 29 as ITR presents a free webinar on integrating tax and finance to improve enterprise performance, forecasting, reporting, and strategic decision-making

Kapil Sethi and Mithilesh Reddy of Steadfast Business Consulting examine why financial transactions remain a transfer pricing battleground six years after the OECD’s Chapter X guidance, and what taxpayers should do about it

New battle lines are being drawn in tax audits and litigation concerning implicit support. Tânia Rodrigues and Pablo Gil Diez De Leon of Deloitte examine how European courts and tax authorities are addressing the issue

Kerwin Chung of Deloitte Tax LLP (United States) explains how IRS Notice 2025-04 could shape US adoption of amount B and simplify transfer pricing compliance for qualifying transactions

Eric Linge, Vrajesh Dutia, and Ewan Kemsley of Deloitte challenge the routine use of interquartile ranges in transfer pricing, arguing that broader statistical approaches can produce more robust comparability analyses

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente illustrate the key phases and examine how multinational enterprises can manage intercompany pricing from planning through implementation, compliance, and tax controversy

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 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.

I. Introduction

Economic substance has assumed an increasingly important role in international tax disputes. Its application, however, requires a clear distinction between the accurate delineation of the actual transaction, the substance-over-form principle, and other anti-avoidance doctrines. Conflating these standards can weaken both the taxpayer’s position and the legal basis for a tax adjustment.