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

Mithilesh Reddy of Steadfast Business Consulting concludes the series by analysing the Dutch Tobacco BV ruling and approaches to transfer pricing guarantee fees in the Netherlands, India, and the UAE

India’s Finance Act, 2026 introduces a tax framework for foreign companies using local data centres but leaves several questions unresolved, say S Vasudevan, Prachi Bharadwaj, and Loveena Manaktala of Lakshmikumaran & Sridharan

Ratna Shakira Lie and Yoan Putra Muda of GNV Consulting explain Indonesia’s new tax guidance in light of insurance accounting changes and highlight its implications for income recognition and compliance

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

In the first article of a three-part series, Mithilesh Reddy of Steadfast Business Consulting decodes a memorandum issued by the Dutch tax authorities that addresses implicit support and recharacterisation, and explains the implications for multinationals

Mithilesh Reddy of Steadfast Business Consulting continues his analysis of the May 2025 memorandum issued by the Dutch Coordination Group on Transfer Pricing, focusing on the conditions that guarantee fees must meet

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss the recently published Provisional Measure 1262/24 and Normative Instruction 2228/24 as a statement of Brazil's commitment to the OECD's global tax standards

Carlos Jorge Vargas and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explore Paraguay’s appeal to international investors and highlight the country’s competitive tax regime as a particularly significant factor in attracting foreign capital

The Supreme Federal Court has returned to a case that could have a huge economic impact on the federal government, report Paulo Victor Vieira da Rocha and Camila Montenegro Cruz of VRMA Advogados

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