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

Fabian Abi Cakra and Aditya Nugroho of GNV Consulting outline how Indonesia’s new pillar two implementation rules establish registration, filing, reporting, and enforcement procedures for in-scope multinational groups under the global minimum tax regime

Fabian Abi Cakra and Erviyanti Adam of GNV Consulting explain how Indonesia’s revised MSME tax regime preserves the preferential 0.5% rate while tightening eligibility criteria and introducing new anti-avoidance measures aimed at business fragmentation

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

Paolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments

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

Gabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform implementation phase and concerns about pending regulation

Natalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty 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

Digitalisation is driving the auto industry through an evolutionary leap. Stephan Habisch and Andreas Göttert of Deloitte Germany look at the new digital era tax approach that may upturn existing TP practices.

Aengus Barry and Sérgio Moreno of Deloitte UK analyse the tax proposals against the energy and resources sector, a clear example of a sector not often seen as ‘digital’ but for which the digital tax could have great implications.

The OECD’s work around the digitalisation of the economy is proceeding at a rapid pace and many multinational enterprises may be surprised at the scope of changes to the international tax framework. These changes could impact all larger multinationals, not just those that consider themselves part of the digital economy.