The OECD has released its long-awaited transfer pricing guidance on financial transactions. Danny Beeton and Alain Goebel of Arendt & Medernach review the guidance and suggest the best approaches for pricing and documentation.

Hendrik Blankenstein, Tom Lawson and Caterina Colling Russo of Tax Partner AG – Taxand Switzerland present a comparative study on how the OECD’s guidance on financial transactions will impact the characterisation and pricing of inter-company loans for MNEs in Switzerland.

Indonesia has strengthened its tax disputes framework by adapting a more sophisticated procedure when handling advance pricing agreements (APAs) and mutual agreement procedures (MAPs). Charles Setia Oetomo and Felic Setiawan of GNV Consulting Services examine how the developments are an attractive premise for businesses in the region.

Endy Arya Yoga and Dewa Gede Dharma Kusuma of GNV Consulting outline Indonesia's temporary VAT relief for domestic economy-class airline tickets and new legal protections for investors in special debt securities

India has amended its GAAR to protect pre-April 2017 investments, but questions remain over application of the Supreme Court’s Tiger Global interpretation, say S Vasudevan, Giridhar Vasudevan, and Romil Hotwani of Lakshmikumaran & Sridharan

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime

The success of ViDA in creating a harmonised digital reporting framework hinges on EU member states simplifying national VAT reporting obligations, says Fernando Matesanz of Spanish VAT Services

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments

Bárbara Miragaia of MFA Legal & Tech argues that the regime’s restrictive eligibility rules and limited relief for intra-group transactions may constrain its practical benefits

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

Gabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform implementation phase and concerns about pending regulation

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law

Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes

Iva Gyurova and Luca Derqui of Deloitte Luxembourg analyse landmark court decisions on intra-group financing, focusing on arm’s-length interest rates and their alignment with OECD transfer pricing guidance

Kathya Capote Peimbert of Vertex examines how continuous transaction controls expose under‑addressed intercompany transaction risks, and outlines the approach multinationals should take to ensure consistent VAT treatment and improve audit defensibility