The OECD’s global anti-base erosion (GloBE) proposal under pillar two is broader than taxpayers expected. It risks over-complicating international tax before the impact of the BEPS project settles in.

The OECD has embarked upon an ambitious project to redistribute taxing rights around the world in a bid to avoid more unilateral action. Here Pascal Saint-Amans makes the case for the unified approach to pillar one.

Despite being compliant with the law, Netflix continues to face harsh criticism for its European tax arrangements. Andrew Parkes, national technical director at Andersen Tax, reviews the company’s trial by media.

Join 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

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

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