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

When uncertainty becomes the new operating environment, transfer pricing policies must evolve with the business or risk being left behind, say Jobst Wilmanns and Anodri Suchdeve in introducing the Deloitte TP Industry Guide 2026

Szymon Wlazlowski and Aengus Barry of Deloitte analyse how commodity price fluctuations in the energy, resources, and industrials sector are challenging established transfer pricing models and offering new insights

Abhinaya Ramanujam and Marco Heuer of Deloitte examine the transfer pricing questions raised when group financing comes under strain and outline a step-by-step framework for managing the analysis

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance