Expert Analysis

In a series of exclusive interviews, Matthew Gilleard talks to five Brazilian taxpayers from the automobile, chemical, IT and oil and gas industries about recent and future challenges, their relationships with the tax authorities, and what measures they would recommend to authorities and legislators to improve taxpayer-tax authority interactions in the future.

On behalf of our Deloitte colleagues that focus on transfer pricing issues within the Latin American and Caribbean region, I am pleased to present this selected collection of thought papers on relevant developments and issues occurring across the region. Over the past few years, increasing trade and investment flows have fuelled a robust economic growth in many Latin American countries. As a result, it is not surprising that the region has enthusiastically embraced the arm's-length principle and enacted specific legislation to provide more certainty to domestic and foreign investors. A solid statement to this trend can be found in the number of Central American and Caribbean countries that have implemented transfer pricing rules inspired by the OECD's Transfer Pricing Guidelines in the past couple of years.

The Argentine oil and gas sector faces a turning point after the discovery of a large, untouched oil and gas site three years ago which has led to policy changes aimed at maximising the economic benefits for the country. Pablo Belaich, Daniel Dasso and Carlos Casanovas, of EY, analyse the latest developments.

India’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV

Join KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation

Jess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions

Several South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements

Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia

Monika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk

Nicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services