Edward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs.

Juan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.

Shaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany.

S Vasudevan and Prachi Bhardwaj of Lakshmikumaran & Sridharan explain how India’s tax authorities face legal pushback over the Multilateral Instrument’s enforceability, with most favoured nation rulings now affecting its implementation

Jeklira Tampubolon and Dwipa Abimanyu Dewantara of GNV Consulting outline recent developments on import duties, the Directorate General of Taxes’ follow-up on concrete tax data, e-commerce taxation, and free trade zone regulations

Jun Au and Eddie Ahn of DLA Piper Australia analyse the Australian Taxation Office’s framework for applying the third-party debt test and debt deduction creation rules under the country’s new thin capitalisation regime

Jakub Warnieło and Aleksandra Bulaszewska of MDDP outline the key takeaways from a report on Polish tax trends, covering tax inspections, verification activities, tax proceedings, and the business viewpoint

Corina Mîndoiu and Geanina Ciorâță of EY Romania explain how the country’s flat-tax consistency, digital integration, and transparent residency rules continue to attract investors, professionals, and digital nomads from around the world

Solange Dias Nóbrega of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the Portuguese government’s plan to phase out indirect SIFIDE and questions whether ending this R&D tax benefit could hinder innovation and entrepreneurship

Gabriel Caldiron Rezende of Machado Associados comments on the rising concerns about the tax reform transition phase, especially concerning how the old taxes will be calculated during their coexistence with the new system

Gabriel Caldiron Rezende of Machado Associados comments on the prominent role to be played by digital platforms under the new Brazilian VAT regime and the relevant compliance reporting framework

Renata Colafêmina and Rafaela Calçada da Cruz of Machado Associados discuss the test rates and ancillary obligations to be implemented from 2026, as Brazil prepares for its sweeping consumption tax changes

Dinko 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

Niklas Elofsson and Vsevolod Konyshev of KPMG Sweden explore how tax functions can unlock demonstrable efficiency gains by using generative AI tools in a budget-constrained transformation landscape

Johannes Bangum, Maria Barenfeld, and Peter Nilsson of KPMG Sweden explain the main pillar two issues that arise in corporate acquisitions, including scope acceleration, top-up tax responsibilities, and earnout treatment