Expert Analysis

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

Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures

Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness

Kapil Sethi and Mithilesh Reddy of Steadfast Business Consulting examine why financial transactions remain a transfer pricing battleground six years after the OECD’s Chapter X guidance, and what taxpayers should do about it

Interview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico

Rob van der Woude of Fonoa argues that AI will not reduce tax work but transform it, making connected data infrastructure the foundation of compliance and competitive advantage

Silvana Blanco, Joel Morante, and Felipe Prado of Deloitte examine how transfer pricing is being reshaped in Argentina, Chile, and Uruguay through closer scrutiny of governance, value creation, operating models, and pillar two implications

Mauro Mascareño, Carlos Jorge Vargas, and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explain how Paraguay’s territorial tax system, investment incentives, and residence pathways are attracting foreign investors amid strong economic performance

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

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