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

Several key rulings clarify the taxation of cross-border payments as royalties with respect to ‘information concerning industrial, commercial or scientific experience’, say S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan

Kelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions

Paul Ashburn, Radapak Arthapridi, and Anna Selina De Vera of HLB Thailand explain how the update to the Commentary on Article 5 clarifies when employees’ homes may create a taxable permanent establishment in the country

Michael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept

The country is in transition as decades of emigration, increasing immigration, and the Ukraine conflict create new economic risks and opportunities, say Corina Mîndoiu and Iulian Pasniciuc of EY Romania

Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse how intragroup software distribution transactions are classified and transfer pricing methods applied, focusing on the interaction between OECD guidance, Italian legislation, and case law

Carlos Ayub of Deloitte Brazil discusses how planned accession to the OECD will affect transfer pricing (TP) in Brazil, and also provides an update on the consequences of discontinuing the Libor rate.

The transfer pricing (TP) audit environments in Argentina and Chile show no sign of relaxing. Silvana Blanco and Vanesa Lanciotti of Deloitte set out how to enter the audit in a position of strength.

Colombia, Peru, and Venezuela have taken steps to update their tax legislation, suggesting that the Andean states are paying closer attention to compliance, write Bruno Urrieta Farías, Jenny Morón and Iliana Salcedo of Deloitte.

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

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