As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda

India's tax authorities are increasingly scrutinising the rationale behind cross-border structures

The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward

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

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Rob van der Woude of Fonoa argues that AI will not reduce tax work but transform it, making connected data infrastructure the foundation of compliance and competitive advantage

Methodology

Dear readers:

The OECD's base erosion and profit shifting (BEPS) project, commissioned by the G20, has now taken centre stage in global transfer pricing.

Economic substance has assumed an increasingly important role in international tax disputes. Its application, however, requires a clear distinction between the accurate delineation of the actual transaction, the substance-over-form principle, and other anti-avoidance doctrines. Conflating these standards can weaken both the taxpayer’s position and the legal basis for a tax adjustment.

SMPS Legal fortalece su práctica de Litigio y Consultoría Fiscal con Patricia López Padilla Barrera como consejera

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