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

Rodrigo Winter of PwC Chile outlines the expected effects of the government’s proposal aimed at reviving a residential real estate sector weakened by years of stagnation

Sandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions

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

Alison Lobb and Howard Osawa of Deloitte explore potential areas of controversy arising from the G20/OECD’s pillar one and pillar two project and considerations to manage disputes and potential double taxation.

Manisha Gupta, Iva Georgijew and Bhupendra Kothari of Deloitte discuss the transfer pricing risks that may arise due to business disruptions caused by COVID-19 with recommendations on how to manage those risks.

Ariel Krinshpun, James Mahon and Mo Malhotra of Deloitte explain why taxpayers may wish to review intra-group financing arrangements, and significant financing transactions in particular, for controversy risk.