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

Fernando Matesanz of Spanish VAT Services examines how Case C-515/24 clarifies the scope of the VAT Directive’s standstill clause, with ramifications for Spain and beyond

Tax risk is that faced by companies that may be paying or accounting for an incorrect amount of tax (including income tax and indirect taxes), or that the tax positions taken by a company are incompatible with the tax risk expectations that administrators have approved or consider prudent.

In Indonesia’s tax administration framework, the Surat Permintaan Penjelasan atas Data dan/atau Keterangan (SP2DK) plays an increasingly prominent role in the Directorate General of Taxes’ compliance strategy. Designed as a pre-audit clarification mechanism, SP2DK reflects the tax authority’s shift toward data-driven supervision. However, from a legal certainty perspective, SP2DK presents structural ambiguities that merit closer examination.