A recent decision underlines that Indian courts are more willing to look beyond just legal compliance and examine whether foreign investment structures have real business substance

Countries that care about the fair taxation of tech multinationals and equitable global distribution of wealth should back the UN’s tax framework, writes economist Abdelmalek Riad

Heads of tax need to push their teams forward as strategic business advisers to add value across their organisations, says Sandy Markwick

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

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Rob 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

Deloitte 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

Mauro Mascareño, Carlos Jorge Vargas, and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explain how Paraguay’s territorial tax system, investment incentives, and residence pathways are attracting foreign investors amid strong economic performance

Romain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation

Antonio Ruiz and José Pablo Artavia of EY Central America, Panama, and the Dominican Republic explain how technology, data, and the integration of tax and finance functions can help organisations build a competitive advantage

Federico 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

Simón 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