Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
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Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
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Sponsored by CMSTax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk -
Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados examines the debate concerning the inclusion of CBS and IBS in the ICMS taxable base and considers whether increased litigation may be on the horizon
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Sponsored by Lakshmikumaran & SridharanRaghav Rajeev and Nimrah Ali of Lakshmikumaran & Sridharan analyse the approaches taken by taxpayers and Indian judicial bodies on contested tax payments under the country’s goods and services tax law
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The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
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The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
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In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
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The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
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Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
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The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
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Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
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DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
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Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
