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Direct Tax
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
August 12, 2026
features sponsored features special focus local insights
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Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences -
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
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More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
Sponsored Features
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Sponsored by Steadfast Business ConsultingKapil 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
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Sponsored by DeloitteInterview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico
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Sponsored by FonoaRob van der Woude of Fonoa argues that AI will not reduce tax work but transform it, making connected data infrastructure the foundation of compliance and competitive advantage
Special Focus
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Sponsored by Deloitte Central AmericaSimón Somohano, Aranzazú Estrada, and Mario Coyoy of Deloitte explore the shift towards risk-based transfer pricing audits in Mexico and Central America and suggest how multinationals can move from a documentation-centred approach towards a broader model
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Sponsored by DeloitteDeloitte tax partners examine how tax authorities in Colombia, Peru, Ecuador, and Venezuela are shifting transfer pricing audits from pricing analysis to economic substance and evidentiary support
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Sponsored by DeloitteSilvana Blanco, Joel Morante, and Felipe Prado of Deloitte examine how transfer pricing is being reshaped in Argentina, Chile, and Uruguay through closer scrutiny of governance, value creation, operating models, and pillar two implications
Local Insights
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente outline key transfer pricing documentation requirements in Italy, highlighting the upcoming tax return filing deadline and the importance of master and local file consistency
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Sponsored by GNV ConsultingCharles Setia Oetomo and Arip Prastyo Wibowo of GNV Consulting outline Indonesia’s new rules on tax representatives and explain a fresh VAT collection mechanism for cross-border digital transactions
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Sponsored by Pérez-LlorcaSusana Estêvão Gonçalves of Pérez-Llorca analyses how the decision restricts Portugal’s real estate transfer tax and may affect similar regimes across the EU
