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

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

The Incentive to the Capitalisation of Companies (Incentivo à Capitalização de Empresas – “ICE”), introduced by the 2023 State Budget, was implemented in the broader context of the discussions at EU level surrounding the proposed Debt-Equity Bias Reduction Allowance (DEBRA) initiative, by promoting equity financing through the introduction of a notional interest deduction – the tax incentive. By establishing a "notional interest" deduction system with deductibility caps that are significantly more generous than those applicable to net financing costs under the general Portuguese interest barrier rule, the ICE has effectively enabled a hybrid approach to corporate capitalisation – one that combines the economic substance of equity with a tax deduction that mirrors the treatment traditionally reserved for debt financing.

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services