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

In the evolving landscape of international taxation, transfer pricing remains a cornerstone of compliance for multinational enterprises. At the heart of this discipline lies the use of comparability analyses - benchmarking studies that assess whether intra-group transactions are conducted at arm’s length, by comparing them to similar transactions between independent entities.

Gabriel Caldiron Rezende of Machado Associados examines the debate concerning the inclusion of CBS and IBS in the ICMS taxable base and considers whether increased litigation may be on the horizon

On the 21 November, the Department of Finance issued its Feedback Statement containing a Strawman Proposal on “Phase 1 of Reform of Ireland’s Taxation Regime for Interest”.