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Direct Tax
As joint audits, data sharing and pillar two reshape tax controversy, multinational groups can no longer afford to manage disputes one jurisdiction at a time
September 9, 2026
features sponsored features special focus local insights
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Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems -
The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
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Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners
Sponsored Features
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Sponsored by insightsoftwareJoin insightsoftware on September 29 as ITR presents a free webinar on integrating tax and finance to improve enterprise performance, forecasting, reporting, and strategic decision-making
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Sponsored by Steadfast Business ConsultingKapil 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
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Sponsored by DeloitteInterview with Mauricio Martínez D’Meza, S-LATAM tax controversy leader, Deloitte Mexico
Special Focus
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Sponsored by DeloitteWhen uncertainty becomes the new operating environment, transfer pricing policies must evolve with the business or risk being left behind, say Jobst Wilmanns and Anodri Suchdeve in introducing the Deloitte TP Industry Guide 2026
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Sponsored by DeloitteSzymon Wlazlowski and Aengus Barry of Deloitte analyse how commodity price fluctuations in the energy, resources, and industrials sector are challenging established transfer pricing models and offering new insights
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Sponsored by DeloitteAbhinaya Ramanujam and Marco Heuer of Deloitte examine the transfer pricing questions raised when group financing comes under strain and outline a step-by-step framework for managing the analysis
Local Insights
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Sponsored by DeloitteXavier Sotillos Jaime and Inês Teixeira of Deloitte Luxembourg explore how multinational manufacturers should address industrial data in transfer pricing models as smart factories reshape value creation, investment, and risk allocation
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Sponsored by Lakshmikumaran & SridharanS Vasudevan, Ravi Sawana, and Samyak Lohade of Lakshmikumaran & Sridharan examine the Delhi High Court’s EY US ruling and its implications for real-employer status, service permanent establishments, and fees for technical services
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Sponsored by Spanish VAT Services AsesoresFernando Matesanz of Spanish VAT Services analyses a judgment confirming that retaining and leasing business premises in a transfer of a going concern may trigger input VAT adjustments
