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

ITR hears how Pérez-Llorca, Miranda & Amado is integrating senior former Deloitte practitioners and building one of Peru’s largest tax teams, and why law firm tax practices should move towards a multidisciplinary model

A discipline once confined to documentation binders now finds itself central to the global tax governance agenda. Maulik Doshi of Nexdigm says AI is rewriting transfer pricing on both sides of the audit table

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

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

S Vasudevan, Giridhar Vasudevan, and Khushi Manchanda of Lakshmikumaran & Sridharan examine how the Paul Wurth ruling may reshape application of the force of attraction rule and profit attribution under Indian tax treaties

Fernando Matesanz of Spanish VAT Services examines how recent CJEU rulings clarify when digital platforms are deemed suppliers for VAT purposes

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici examine whether effective tax cooperation can justify extending cadastral valuation beyond the EU and European Economic Area

Martinelli Advogados has strengthened its Tax practice with the arrival of two new partners, expanding the firm’s capabilities in Rio de Janeiro and Pernambuco and responding to growing demand for tax advice that is more closely integrated with business decision-making.

AKD welcomes Alexandre Hübscher as a partner in its investment funds practice in Luxembourg, effective 1 October. He advises national and international clients on asset management and investment funds, with a focus on private equity, real estate, debt and infrastructure funds. His arrival strengthens AKD’s investment funds practice and further supports the firm’s ambition to develop its Luxembourg practice as part of its broader Benelux strategy.

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”).