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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 DeloitteHelen Cousineau, Nicola Lostumbo, and Pablo Renieblas of Deloitte examine how companies can manage tariff impacts on supply chains through transfer pricing and customs valuation, highlighting common challenges and strategies for mitigating related risks
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Sponsored by DeloitteTax authorities are tightening their focus on intercompany loans, guarantees, and cash pooling. George Galumov and Immacolata Abbamondi of Deloitte explain how multinational enterprises can mitigate risks in financial transactions transfer pricing
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Sponsored by DeloitteCarlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges
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
