Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse Ordinance No. 18145/2026, focusing on transfer pricing method selection and the distinction between taxable prize promotions and contractual arrangements involving reciprocal obligations

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici examine whether effective tax cooperation can justify extending cadastral valuation beyond the EU and European Economic Area

Marta 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

Experience often shapes tax technology decisions, but Kathya Capote Peimbert of Vertex argues that familiarity should not be mistaken for evidence when evaluating enterprise architectures

Federico 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

Xavier 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

Simón 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

Silvana 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

Renata 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

Ratna Shakira Lie and Terananda Prastiti Anggaraita of GNV Consulting examine Indonesia's latest tax developments, including Coretax-related reporting reforms, a new VAT collection mechanism for foreign digital transactions, and government securities incentives

S Vasudevan, Giridhar Vasudevan, and Khushi Manchanda of Lakshmikumaran & Sridharan examine how the Paul Wurth ruling may reshape application of the force of attraction rule and profit attribution under Indian tax treaties

Amit 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

Mithilesh 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

Rabie 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

Rabie 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