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

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

Experience often shapes tax technology decisions, but Kathya Capote Peimbert of Vertex argues that familiarity should not be mistaken for evidence when evaluating enterprise architectures

Marta Klepacz of MDDP says a clear allocation of responsibilities and data testing are among the good practices multinational groups should adopt as public country-by-country reporting takes effect

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

In the recent case of Upayapadu (M) Sdn Bhd (“Taxpayer”) v Ketua Pengarah Hasil Dalam Negeri1, the Taxpayer was successful in its judicial review application against the Director General of Inland Revenue’s (“DGIR”) decision to subject certain sums received by the Taxpayer pursuant to a settlement agreement (“Settlement Agreement”) to income tax even though the Settlement Agreement was entered into in consideration for the relinquishment of certain rights and licences held by the Taxpayer to the relevant authorities (“the Rights”).

In the recent case of Syarikat Pembinaan D.S.R. Sdn Bhd ("Taxpayer") v Director General of Customs and Excise [Civil Appeal No. K-01(A)-58-02/2023], the Taxpayer successfully appealed to the Court of Appeal against the High Court's decision, which upheld the Director General of Customs and Excise’s ("Customs") refusal to give effect to the exemption under section 155 of the Goods and Services Tax Act 2014 (“the Exemption”). Under section 155, taxable supplies of goods or services made within a “designated area” (i.e. Labuan, Langkawi and Tioman) are exempted from goods and services tax (“GST”).

VSTN has been authorised by HMRC as a software provider for Pillar Two reporting in the United Kingdom.