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Sophie Brown and Sarah Blakelock of Deloitte highlight the lessons to be learnt from transfer pricing disputes and case law as tax authorities increasingly pursue data interrogation, source data, and access to emails.

Eddie Morris of Deloitte considers the limited evidence available on the use of the arbitration clause of mutual agreement procedure articles to resolve transfer pricing disputes, and pinpoints areas for improvement.

Santiago Llano and Eric Palacios of Ritch Mueller explain why non-Mexican residents should analyse whether Mexican source income exists when transferring participation in a non-Mexican resident entity that owns directly or indirectly immovable property in Mexico.

In collaboration with EY, ITR’s guide to the tax-related developments, challenges, and strategies in the Asia-Pacific region emphasises how connected the world has become.

Eng Ping Yeo of EY identifies three ‘megatrends’ that governments and businesses should be aware of as they consider their tax policies in a challenging and rapidly evolving environment.

Luis Coronado and Matt Andrew of EY unpick the OECD’s consultation documents related to tax certainty under pillar one and find that there are many unresolved issues in terms of tax dispute resolution.

Luis Coronado and Matt Andrew of EY say policymakers still have many issues to resolve as debates continue over the technical and implementation-related elements of pillars one and two.

There is little time to waste as companies and tax departments prepare for the implementation of BEPS 2.0 at the start of 2024, report Albert Lee and Carina Ngai of EY.

The indicators point in one direction: an increase in tax controversy, as authorities’ resources are ploughed into increased scrutiny. Luis Coronado of EY explains why, and suggests what tactics businesses should be adopting.