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Transfer Pricing
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
August 6, 2026
features sponsored features special focus local insights
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Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test -
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
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Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
Sponsored Features
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Sponsored by DeloitteInterview with Tammy Arendse, tax litigation, advisory, and settlement partner (tax controversy), Deloitte UK
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Sponsored by CuatrecasasAna Helena Farinha, Tiago Martins de Oliveira, and Catarina Leão of Cuatrecasas provide a guide to a controversial tax incentive regime that is facing further amendments under the 2024 Portuguese State Budget Law
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Sponsored by Dhruva AdvisorsDhruva tax experts Mehul Bheda, Kulraj Ashpnani and Ashish Agrawal review a whirlwind year for tax in India, in an exclusive podcast with ITR
Special Focus
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Sponsored by ATOZRomain Tiffon and Marie Bentley of ATOZ analyse how automation, data analytics, and generative AI are reshaping tax operations, enabling greater strategic insight while raising important challenges around data, governance, and implementation
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Sponsored by Tax PartnerStephanie Eichenberger and Victoria Riep of Tax Partner provide a guide to Switzerland’s securities transfer tax for domestic and foreign investors, explaining when it is triggered and how to mitigate unexpected tax consequences
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Sponsored by YulchonSeveral South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements
Local Insights
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Sponsored by MDDPJakub Warnieło and Agnieszka Walska of MDDP outline the tax risks attracting the greatest scrutiny in Poland and explain how foreign investors can reduce audit exposure through proactive compliance
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Sponsored by MDDPAnna Misiak, Rafał Sidorowicz, and Agnieszka Telakowska-Harasiewicz of MDDP explain how Poland’s new labour inspection framework affects foreign employers and why flexible workforce models remain available when supported by appropriate governance and compliance measures
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Sponsored by MFA Legal & TechJoana Lobato Heitor and Bárbara Miragaia of MFA Legal & Tech explain how recent EU judgments are strengthening foreign investors’ claims for refunds of Portuguese withholding tax
