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Transfer Pricing
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
July 10, 2025
features sponsored features special focus local insights
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New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer -
AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
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Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
Sponsored Features
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Sponsored by KPMG ChinaSunny Leung and Conrad Turley of KPMG China offer an overview of the varied implications of the much-anticipated BEPS 2.0 rollout across Asia Pacific.
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Sponsored by Vertex IncFactors such as a saturated market and challenging economic headwinds are threatening to bring an end to the SaaS ‘sugar rush’. Niall Kiernan of Vertex considers how businesses in this sector can prepare.
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Sponsored by YulchonKyu Dong Kim, Min Young Sung, Joon Yung Jo and Ellie Jin of Yulchon report that foreign companies receiving Korean-sourced income are now required to disclose information about their financials and investors to access treaty benefits.
Special Focus
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Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile
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Sponsored by DeloitteSenior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica
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Sponsored by DeloitteSenior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation
Local Insights
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Sponsored by VRMA AdvogadosThe protocol amending the Brazil–China double tax treaty is aimed at improving legal certainty, reducing withholding taxes, and preventing treaty abuse, say Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados
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Sponsored by EY RomaniaMihai Petre and Cosmin Dincă of EY Romania explain how getting customs essentials right – from classification and origin to valuation – can reduce fiscal exposure and improve operational certainty for importers
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Sponsored by VdAFrancisco Cabral Matos and Francisca de Landerset of VdA examine Portugal’s tax neutrality regime for mergers and demergers, highlighting how rigid interpretations by the tax authority are undermining its practical application
