In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures

Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

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

Xavier 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

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