Mithilesh Reddy of Steadfast Business Consulting says multinationals must adopt proactive governance and robust compliance practices as the region’s transfer pricing environment develops at pace

Rabie Morsy and Ahmed Khalifa of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt analyse the amendments and guidance, focusing on construction, commodities, exemptions, and practical compliance implications for businesses

Rabie Morsy and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt assess the package’s impact on dispute resolution, investment structures, and administrative efficiency

Several key rulings clarify the taxation of cross-border payments as royalties with respect to ‘information concerning industrial, commercial or scientific experience’, say S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan

Kelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions

Paul Ashburn, Radapak Arthapridi, and Anna Selina De Vera of HLB Thailand explain how the update to the Commentary on Article 5 clarifies when employees’ homes may create a taxable permanent establishment in the country

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Patrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines

Nicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications

Rodrigo Winter of PwC Chile outlines the expected effects of the government’s proposal aimed at reviving a residential real estate sector weakened by years of stagnation

Sandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions

Gabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty

Dinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes

Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg