LEAD ARTICLE
LEAD ARTICLE
Sponsored
Sponsored by
Crowe Valente/Valente Associati GEB Partners
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse how intragroup software distribution transactions are classified and transfer pricing methods applied, focusing on the interaction between OECD guidance, Italian legislation, and case law
March 17, 2026
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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 -
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
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Sponsored by DLA Piper AustraliaKelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions
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Sponsored by HLB ThailandPaul Ashburn, Radapak Arthapridi, and Anna Selina De Vera of HLB Thailand explain how the update to the Commentary on Article 5 clarifies when employees’ homes may create a taxable permanent establishment in the country
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Sponsored by GNV ConsultingDewa Nugraha and Julius Wahyu Daryono of GNV Consulting summarise new tax data reporting rules, guidance on the taxation of domestic dividends, and transitional relief related to the Coretax system
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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 analyse how intragroup software distribution transactions are classified and transfer pricing methods applied, focusing on the interaction between OECD guidance, Italian legislation, and case law
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Sponsored by Gatti Pavesi Bianchi LudoviciGloBE reporting obligations following the side-by-side package’s introduction: an evolving frameworkPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici consider what to expect with regard to global minimum tax reporting obligations following the implementation of the side-by-side package
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services examines how Case C-515/24 clarifies the scope of the VAT Directive’s standstill clause, with ramifications for Spain and beyond
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Sponsored by PwC ChileSandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the latest developments related to the beginning of the Brazilian consumption tax reform test phase and considers the next steps
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Sponsored by PwC ChileRodrigo Winter Salgado of PwC Chile outlines the country's proposed foreign investment regime, comparing it with past frameworks and highlighting potential tax and legal protections for local and international investors
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Sponsored by Vertex IncChris Hall of Vertex explains how e-invoicing is becoming essential for multinational businesses, enabling compliance, operational efficiency, and friction-free participation in global trade amid increasingly digital tax regimes
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosBernardo Mesquita of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines how AI can enhance tax administration efficiency while raising significant transparency, accountability, and taxpayer-rights concerns that governments must address
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Sponsored by Deloitte LuxembourgDinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied
