As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda

India's tax authorities are increasingly scrutinising the rationale behind cross-border structures

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

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

Silke Lappe and Karen Smolka of Deloitte Germany examine transfer pricing challenges and governance considerations for cybersecurity and generative AI services, highlighting how emerging technologies are reshaping value chains, compliance demands, and multinational tax approaches

Richard Schmidtke, Heike Schenkelberg, and David Sauer of Deloitte Germany explore how changing tax incentives, trade barriers, and evolving transfer pricing regulations affect life sciences and healthcare companies operating complex, global value chains

Szymon Wlazłowski and Igor Fudali of Deloitte Central Europe explain why transfer pricing economic analyses must now adapt to inflation, supply chain shocks, and trade tensions to remain robust and defensible

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.

SMPS Legal fortalece su práctica de Litigio y Consultoría Fiscal con Patricia López Padilla Barrera como consejera