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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 DeloitteCarlos Ayub of Deloitte Brazil explores the government’s move to regulate advance pricing agreements as the country aligns its transfer pricing framework more closely with OECD standards
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Sponsored by Tax PartnerStephanie Eichenberger and Thomas Zellweger of Tax Partner explain how the choice of investment vehicle impacts the eligibility of non-Swiss investors for Swiss withholding tax refunds and, ultimately, investment performance
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Sponsored by Copper WolfRicardo Villalobos of Copper Wolf examines how BEPS pillars one and two reshape global tax rules, potentially affecting domestic systems and closing gaps in multinational corporate tax avoidance
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
