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Transfer Pricing
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
June 18, 2026
features sponsored features special focus local insights
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HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented -
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
Sponsored Features
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Sponsored by DeloitteRonnie Dassen and Jan De Clercq of Deloitte Global outline how agentic AI can support indirect tax teams in managing compliance pressures, improving data quality, and freeing capacity for higher-value advisory work
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Sponsored by DeloitteSameer Nurmohamed, partner, Deloitte Legal Canada
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Sponsored by DeloitteGeorge Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)
Special Focus
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Speaking to taxpayers in Latin America, it is clear that discontent is one emotion that dominates their feeling towards a region that is not afraid to diverge from standard practices, and where distrust between taxpayers and tax authorities often abounds.
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On the face of it, indirect tax is the better option for companies. Unlike direct taxes on their profits, taxes on consumption can, for the most part, be passed on. As such, companies around the world have welcomed a global trend of falling corporate tax rates offset by higher rates of VAT/GST.
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With tax avoidance under an unprecedented level of international scrutiny, the world's major holding company locations are facing turbulent times.
Local Insights
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Sponsored by Lakshmikumaran & SridharanIndia has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan
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Sponsored by GNV ConsultingFabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime
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Sponsored by GNV ConsultingFabian Abi Cakra and Erviyanti Adam of GNV Consulting explain how Indonesia’s revised MSME tax regime preserves the preferential 0.5% rate while tightening eligibility criteria and introducing new anti-avoidance measures aimed at business fragmentation
