Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Deloitte’s practitioners from across the globe report on four of the most prominent transfer pricing (TP) controversy cases from the recent past: Adecco (Denmark), Glencore (Australia), Cameco (Canada), and Philips (France).
Eric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations.
Kerwin Chung and Iva Georgijew assess the impact of the coronavirus pandemic on global transfer pricing and consider how the concept of the arm’s-length principle will subsequently evolve.
