As global capability centres use AI to deliver services, MNEs face a fresh wave of PE and TP exposure that their existing playbooks weren't built for

Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector

As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands

Michele Aprile and Michele Bissoli of Gatti Pavesi Bianchi Ludovici analyse the implications of recent Supreme Court decisions that may allow taxpayers to obtain treaty relief from double taxation and pursue historical refund claims

McCarthy Tétrault tax practitioners explain Canada’s proposed Productivity Mega Deduction, and related tax changes aimed at boosting investment, competitiveness, and certainty for major capital projects

ITR hears how Pérez-Llorca, Miranda & Amado is integrating senior former Deloitte practitioners and building one of Peru’s largest tax teams, and why law firm tax practices should move towards a multidisciplinary model

Carlos Serrano Palacio, Inka Traeger, and Bernardo Misle of Deloitte introduce the 2026 Deloitte TP Controversy Guide, highlighting the transfer pricing developments, dispute prevention tools, and audit trends reshaping controversy management worldwide

Jamie Bedford, Henning Scheibe, and Miller Williams Jr. of Deloitte examine how US tax law changes are encouraging multinational enterprise groups to revisit US-centred intellectual property and operating models, and how European tax authorities are responding

Alexander Duric and Rachel Ney of Deloitte explain how the OECD’s updated mutual agreement procedure manual clarifies best practices for dispute resolution and may help businesses achieve greater tax certainty

Xavier Sotillos Jaime and Luca Derqui of Deloitte Luxembourg outline the key public country-by-country reporting obligations, filing routes, and compliance considerations for non-EU UPE groups operating in Luxembourg

Claudia Sofianu of EY Romania examines how SAF-T and other digital reporting initiatives could foreshadow greater payroll scrutiny, highlighting the governance, data-quality, and compliance challenges organisations should address now

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse Ordinance No. 18145/2026, focusing on transfer pricing method selection and the distinction between taxable prize promotions and contractual arrangements involving reciprocal obligations

This article analyzes the concept of beneficial owner in the tax treaties entered into by Mexico for the avoidance of double taxation, as well as its role as a requirement for access to the benefits provided by those instruments with respect to dividends, interest, and royalties.

Oportunidad fiscal, riesgos de fiscalización y criterios de decisión para empresarios

La consolidación de la fiscalización basada en la realidad económica y sus límites cautelares