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Direct Tax
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
August 12, 2026
features sponsored features special focus local insights
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Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure -
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
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Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
Sponsored Features
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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
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Sponsored by FonoaRob 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
Special Focus
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Sponsored by DeloitteSzymon Wlazłowski and Igor Fudali of Deloitte Central Europe explain why transfer pricing economic analyses must now adapt to inflation, supply chain shocks, and trade tensions to remain robust and defensible
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Sponsored by DeloitteStephan Habisch and Florence Müller of Deloitte Germany examine how tariffs disrupt transfer pricing, forcing multinationals to reassess supply chains, manage compliance risks, and explore strategic restructuring to balance challenges with emerging opportunities
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Sponsored by DeloitteBernardo Misle, Andrea Guevara, and Wissal Ritoune of Deloitte Spain offer strategies to manage transfer pricing disputes amid evolving OECD guidelines and increasing scrutiny of value chains by tax authorities
Local Insights
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Sponsored by GNV ConsultingCharles Setia Oetomo and Arip Prastyo Wibowo of GNV Consulting outline Indonesia’s new rules on tax representatives and explain a fresh VAT collection mechanism for cross-border digital transactions
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Sponsored by Pérez-LlorcaSusana Estêvão Gonçalves of Pérez-Llorca analyses how the decision restricts Portugal’s real estate transfer tax and may affect similar regimes across the EU
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Sponsored by MDDPJakub Warnieło and Agnieszka Walska of MDDP outline the tax risks attracting the greatest scrutiny in Poland and explain how foreign investors can reduce audit exposure through proactive compliance
