LEAD ARTICLE
LEAD ARTICLE
Sponsored
Sponsored by
Vertex Inc
Europe
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Sponsored by MDDPMarta Klepacz of MDDP says a clear allocation of responsibilities and data testing are among the good practices multinational groups should adopt as public country-by-country reporting takes effect
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Sponsored by DLA PiperA recent publication may ease concerns about the application of the anti-abuse rule under the Dutch dividend withholding tax exemption. Jian-Cheng Ku and Roland Kleimann of DLA Piper Netherlands analyse the implications
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente outline key transfer pricing documentation requirements in Italy, highlighting the upcoming tax return filing deadline and the importance of master and local file consistency
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente illustrate the key phases and examine how multinational enterprises can manage intercompany pricing from planning through implementation, compliance, and tax controversy
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Sponsored by DeloitteXavier Sotillos Jaime and Inês Teixeira of Deloitte Luxembourg explore how multinational manufacturers should address industrial data in transfer pricing models as smart factories reshape value creation, investment, and risk allocation
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Sponsored by Deloitte LuxembourgBalazs Majoros and Oleg Tupchii of Deloitte Luxembourg examine the Singapore Telecom case and its implications for intra-group financing, implicit support, parental guarantees, and arm’s-length interest rates
Latin America & Caribbean
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Sponsored by Deloitte Central AmericaSimón Somohano, Aranzazú Estrada, and Mario Coyoy of Deloitte explore the shift towards risk-based transfer pricing audits in Mexico and Central America and suggest how multinationals can move from a documentation-centred approach towards a broader model
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Sponsored by DeloitteSilvana Blanco, Joel Morante, and Felipe Prado of Deloitte examine how transfer pricing is being reshaped in Argentina, Chile, and Uruguay through closer scrutiny of governance, value creation, operating models, and pillar two implications
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Sponsored by MachadoRenata Colafêmina and Rafaela Calçada da Cruz of Machado Associados comment on how the consumption tax reform could affect the taxation of carbon assets and environmental projects
Asia-Pacific
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Sponsored by HLB ThailandAmit Bhalla and Anchalee Singh of HLB Thailand explain how value chain analysis helps align transfer pricing outcomes with value creation, supporting functional analysis, documentation, and compliance
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Sponsored by GNV ConsultingThe latest Indonesian developments include a postponement of Article 22 withholding provisions for marketplaces, Coretax-related updates, and clarification of crypto-asset reporting obligations, write Jeklira Tampubolon and Danang Syailendra of GNV Consulting
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Sponsored by Lakshmikumaran & SridharanS Vasudevan, Ravi Sawana, and Samyak Lohade of Lakshmikumaran & Sridharan examine the Delhi High Court’s EY US ruling and its implications for real-employer status, service permanent establishments, and fees for technical services
Africa
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Sponsored by Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting says multinationals must adopt proactive governance and robust compliance practices as the region’s transfer pricing environment develops at pace
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptRabie Morsy and Ahmed Khalifa of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt analyse the amendments and guidance, focusing on construction, commodities, exemptions, and practical compliance implications for businesses
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptRabie Morsy and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt assess the package’s impact on dispute resolution, investment structures, and administrative efficiency