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Expert Analysis

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Transfer Pricing
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
November 20, 2025
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  • As disruption layers new complexity, pressure and opportunity onto business, the digital tax function is rapidly evolving. Shawn Smith, EY global tax technology and transformation leader, explores the needs of organisations as these developments occur.
  • Spain has introduced groundbreaking requirements for companies to file transactional data in near real-time. Joe Stanley-Smith examines the case study of global battery company Duracell to explore how companies are dealing with the extra workload from the Suministro Inmediato de Información (SII) legislation, one month on from its implementation on July 1 2017.
  • The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

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