Expert Analysis

Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments

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

The OECD has issued new guidance on applying the profit-split method (PSM) in the energy and resources (E&R) sector. But will this see an uptick in its use? Deloitte’s Mark Barker and Aengus Barry discuss.

India’s rapid growth and energy consumption has seen the government simplify public-private investment partnerships in the upstream oil and gas (O&G) sector. Deloitte’s Bhavik Timbadia and Ankit Goel discuss the transfer pricing (TP) implications.

As resource-rich Middle Eastern governments suffer a decline in oil revenues, many governments are reforming transfer pricing (TP) regulations to limit capital flight. Deloitte’s Shiv Mahalingham, Alena Kovalova and Claire Boushell discuss the regional regulatory trends.

Romain 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

Stephanie 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

Several 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

Susana Estêvão Gonçalves of Pérez-Llorca analyses how the decision restricts Portugal’s real estate transfer tax and may affect similar regimes across the EU

Jakub 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

Anna 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