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Transfer Pricing
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
May 7, 2026
features sponsored features special focus local insights
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist -
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties
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Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Sponsored Features
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Sponsored by DeloitteJess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions
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Sponsored by DeloitteDeloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead
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Sponsored by DeloitteDave Yaros, tax principal, Deloitte Tax LLP
Special Focus
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Sponsored by CuatrecasasAna Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas provide an overview of the current status of the Portuguese warranty and indemnity insurance and tax insurance market
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Sponsored by Galicia AbogadosAn uptick in nearshoring activities in Mexico has led to heightened interest in trusts that specialise in energy and infrastructure investments. Federico Scheffler, Eduardo Espinosa, and Ileana García of Galicia Abogados explain the nuances
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues
Local Insights
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications
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Sponsored by McCarthy TétraultThe key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault
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Sponsored by Lakshmikumaran & SridharanThe Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan
