As global capability centres use AI to deliver services, MNEs face a fresh wave of PE and TP exposure that their existing playbooks weren't built for

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

From January 2027, Poland will offer a single CIT incentive for investment nationwide. Bartosz Głowacki, Konrad Medoliński, and Paweł Wyciślik of MDDP explain the changes, proposals, and why the country remains attractive to investors

Michele Aprile and Michele Bissoli of Gatti Pavesi Bianchi Ludovici analyse the implications of recent Supreme Court decisions that may allow taxpayers to obtain treaty relief from double taxation and pursue historical refund claims

McCarthy Tétrault tax practitioners explain Canada’s proposed Productivity Mega Deduction, and related tax changes aimed at boosting investment, competitiveness, and certainty for major capital projects

Carlos Serrano Palacio, Inka Traeger, and Bernardo Misle of Deloitte introduce the 2026 Deloitte TP Controversy Guide, highlighting the transfer pricing developments, dispute prevention tools, and audit trends reshaping controversy management worldwide

Jamie Bedford, Henning Scheibe, and Miller Williams Jr. of Deloitte examine how US tax law changes are encouraging multinational enterprise groups to revisit US-centred intellectual property and operating models, and how European tax authorities are responding

Alexander Duric and Rachel Ney of Deloitte explain how the OECD’s updated mutual agreement procedure manual clarifies best practices for dispute resolution and may help businesses achieve greater tax certainty

Jian-Cheng Ku, Roland Kleimann, and Calvin Gu of DLA Piper Netherlands discuss the Dutch consultation regarding withholding tax on services in tax treaties

Conceição Gamito of VdA explores the practical consequences of recent VAT case law for Portugal’s pharmaceutical industry, including refund claims, interest recovery, and related contribution mechanisms

Xavier Sotillos Jaime and Luca Derqui of Deloitte Luxembourg outline the key public country-by-country reporting obligations, filing routes, and compliance considerations for non-EU UPE groups operating in Luxembourg

On 7 October 2026, the Luxembourg Government filed bill of law No. 8800 concerning the State budget for 2027 (the "Bill") with the Chamber of Deputies. Alongside the budget itself, the Bill introduces a package of tax measures designed to increase Luxembourg's tax competitiveness and support businesses, most of which would apply from tax year 2027.

This article analyzes the concept of beneficial owner in the tax treaties entered into by Mexico for the avoidance of double taxation, as well as its role as a requirement for access to the benefits provided by those instruments with respect to dividends, interest, and royalties.

Oportunidad fiscal, riesgos de fiscalización y criterios de decisión para empresarios