Expert Analysis

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

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

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

Jobst Wilmanns and Anna Bolosheva of Deloitte Germany introduce this year’s ITR guide presenting transfer pricing insights across multiple sectors. The articles summarised below feature expert analysis from Deloitte’s international transfer pricing specialists

Camilo Rodríguez, Ricardo Ruiz, and Pedro Madera of KPMG Colombia analyse how the country addresses tax abuse, recent court guidance on the general anti-avoidance rule, and the practical challenges faced by taxpayers and authorities

Indonesia’s appointment of online marketplaces as tax collectors under PMK-37/2025 reshapes e-commerce compliance and merchant obligations, explain Ahdianto and Aditya Wicaksono of GNV Consulting

Charles 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

Susana Estêvão Gonçalves of Pérez-Llorca analyses how the decision restricts Portugal’s real estate transfer tax and may affect similar regimes across the EU

Jakub 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