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

Cross-border cooperation in transfer pricing risk assessments and audits has presented cost saving opportunities, but increased reporting obligations for MNEs. Deloitte’s Manfred Naumann and David Varley explore the experience in Germany and the US.

Transfer pricing (TP) controversies have arisen in all countries. Deloitte’s Eric Lesprit, Sanjay Kumar and Joseph Tobin focus on recent TP controversy developments in three: France, India, and the US.

Mexico’s northern border has always been a contentious zone given its proximity to the world’s largest consumer market: the US. Roberto Padilla Ordaz and Jorge Ramón Galland Ríos of Chevez Ruiz Zamarripa outline the latest taxpayer incentives introduced in the region.

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