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McCarthy Tétrault
Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance
June 3, 2026
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Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning -
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
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In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Sponsored Features
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Sponsored by McCarthy TétraultSenior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance
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Sponsored by KNAV IndiaIndia’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV
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Sponsored by insightsoftwareJoin KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation
Special Focus
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Sponsored by Svalner Atlas AdvisorsPatrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines
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Sponsored by Skeppsbron SkattMichael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept
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Sponsored by Doane Grant ThorntonRoss Harris of Doane Grant Thornton explains how Canadian transfer pricing amendments increase recharacterisation risk and heighten the need for robust documentation and transaction design
Local Insights
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Sponsored by Deloitte LuxembourgJean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
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Sponsored by MFA Legal & TechSamuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
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Sponsored by Deloitte LuxembourgIva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance
