Nouran Ibrahim and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say taxpayers required to submit transfer pricing documentation could avoid penalties by acting in response to a recently published law

Rabie Morsy and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt summarise three laws designed to facilitate the growth of SMEs and business as a whole through simplified tax procedures and incentives

Nouran Ibrahim and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say mutual agreement procedures will have a vital role to play as the country modernises its tax infrastructure

Alex Lebsanft and Sarah Gard of DLA Piper Australia analyse a recent Full Federal Court decision on the Australian Taxation Office’s application of the country’s anti-avoidance rules to treat capital returns as dividends

S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan question the interpretational clarity of the rules and highlight the practical challenges in limiting interest paid to associated enterprises

Indian writ courts are increasingly scrutinising the mechanical invocation of extended limitation under goods and services tax, say Sahana Rajkumar, Derlene Joshna, and R Amrith of Lakshmikumaran and Sridharan Attorneys

The combined effect of the globalisation of entrepreneurial responsibilities within multinationals and the OECD's BEPS initiative puts traditional one-sided transfer pricing (TP) methods under increased pressure. NERA Managing Director Dr Yves Hervé and Associate Director Philip de Homont show how transactional net margin method (TNMM)-type TP solutions can be made sustainable for the future.

Tax incentives in Croatia for research and development (R&D) projects were granted between 2007 and 2014 based on Articles 111 a. to 111 f. of the Act on Scientific Activity and Higher Education. However, the European Union issued Commission Regulation (EU) No. 651/2014 in June 2014, concerning certain categories of state aid; this used significantly different terminology, definitions, and requirements, and rendered the abovementioned articles invalid. Croatian entrepreneurs found themselves in something of a vacuum for more than three years, awaiting a new legal framework for R&D incentives, as the relevant tax incentive had been abolished on January 1 2015. In July 2018, the Croatian Parliament adopted and published the Act on State Aid for Research and Development Projects, which the government had submitted in January 2018.

In general terms, inherence can be described as the relationship between the cost and the enterprise, where the cost has a specific relevance to the determination of income; this is a result of its connection not to a specific revenue, but rather to an activity potentially able to produce income. Based on this assumption, in order to consider a cost deductible (i.e. inherent), the taxpayer is required to demonstrate clearly the connection with the activity, providing the tax authority with "sufficient" documentation.

Gabriel 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

Rodrigo 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

Sandra Benedetto and Nicolás Foppiano of PwC Chile explain the country’s new VAT rules for international purchases, eliminating the $41 exemption and requiring foreign platforms to collect VAT on cross-border sales

Chris 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

Bernardo 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

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