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

From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa

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

When 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

Szymon 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

Abhinaya 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

S 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

Fernando 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

I. Introduction