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

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

Dewa Nugraha and Julius Wahyu Daryono of GNV Consulting summarise new tax data reporting rules, guidance on the taxation of domestic dividends, and transitional relief related to the Coretax system

The country is in transition as decades of emigration, increasing immigration, and the Ukraine conflict create new economic risks and opportunities, say Corina Mîndoiu and Iulian Pasniciuc of EY Romania

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse how intragroup software distribution transactions are classified and transfer pricing methods applied, focusing on the interaction between OECD guidance, Italian legislation, and case law

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici consider what to expect with regard to global minimum tax reporting obligations following the implementation of the side-by-side package

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

Rodrigo Winter Salgado of PwC Chile outlines the country's proposed foreign investment regime, comparing it with past frameworks and highlighting potential tax and legal protections for local and international investors

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

Mark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty