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

Sarah Gard of DLA Piper Australia summarises the Australian Taxation Office’s draft guidance on determining whether the amount of inbound, cross-border related party debt is consistent with the arm’s-length conditions for transfer pricing purposes

Andrew Jackomos and Amit Bhalla of HLB Thailand examine how evolving global tax standards are reshaping the treatment of intragroup royalty payments and driving stricter compliance and documentation requirements

Jun Au of DLA Piper Australia analyses a recent Full Federal Court decision on the Australian Taxation Office’s application of the general anti-avoidance rules, with the judgment also addressing dividend stripping and the taxation of financial arrangements

Ricardo Seabra Moura of Morais Leitão, Galvão Teles, Soares da Silva & Associados analyses how Portugal’s withholding tax rules on interest payments may unlawfully discriminate against companies based in European Economic Area countries

Łukasz Kosonowski and Szymon Konieczny of MDDP examine how Poland’s Estonian-style corporate income tax regime is offering increasing benefits to domestic and foreign investors seeking deferral and lower dividend withholding tax

Victoria Robinson of KPMG Sweden examines the government’s proposal to reduce the rate of special income tax for non-residents to 20% from January 2026 as it strives to enhance tax neutrality and global competitiveness

Paulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados analyse the application of Brazil’s federal tax on industrialised products to intragroup goods transfers, after a ruling that addressed alleged tax planning abuses

Gabriel Caldiron Rezende and Juliana Mari Tanaka of Machado Associados discuss the impact of Brazil’s consumption tax reform on financial services, with a particular focus on the taxation of banking spreads

Gabriel Caldiron Rezende and Rafaela Calçada Cruz of Machado Associados discuss the impacts of the consumption tax reform on agribusiness, focusing on sector-specific concessions, challenges, and strategic responses

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies

Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.

In the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.

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.

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.

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.

Niklas Elofsson and Vsevolod Konyshev of KPMG Sweden explore how tax functions can unlock demonstrable efficiency gains by using generative AI tools in a budget-constrained transformation landscape

Johannes Bangum, Maria Barenfeld, and Peter Nilsson of KPMG Sweden explain the main pillar two issues that arise in corporate acquisitions, including scope acceleration, top-up tax responsibilities, and earnout treatment

Paolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty