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

Ratna Shakira Lie and Yoan Putra Muda of GNV Consulting explain Indonesia’s new tax guidance on insurance accounting changes, addressing the transition to PSAK 117 and its implications for income recognition and compliance

Ratna Shakira Lie and Yoan Putra Muda of GNV Consulting outline Indonesia’s relaxation of sanctions for late 2025 corporate income tax returns and payments, alongside updated rules on preliminary refunds and compliance requirements

The Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan

Nicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application

The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications

Priscila Vergueiro and Mark Conomy of PwC Brazil set out how Brazilian tax authorities have provided guidance on the definition of ‘dependent parties’ for the purpose of goodwill and step-up deductions.

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.

The technological revolution has led the OECD to attempt to redefine the concept of permanent establishments. Antonio A Weffer of Baker & McKenzie Luxembourg discusses how the related notion of the finance function is evolving in a digital cross-border setting.

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

Diana Lupu and Ana-Maria Nițu of EY Romania explain when entities subject to the global minimum tax can transition to IFRS, the key benefits and challenges, and the implications for financial reporting and compliance

Sal Visca of Vertex explains why tax professionals and authorities must evolve to keep pace with developments such as AI-executed transactions and real-time reporting