Intra-group guarantees and TP: Italian Supreme Court endorses a substance-based approach
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications
TP and the Corporate Tax Roadmap: reform by momentum, not revolution
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
Pillar two’s first compliance test: what advisers should be telling clients
With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks
Canada in midst of ‘exceptionally active period of tax reform’
The key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault
TP audits are moving upstream, but can African authorities keep pace?
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
‘More refined’: advisers dissect updated ATO TP guidance
Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined
‘Taxpayers are thrilled’: local experts hail record-breaking Indian APAs
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Italy: Cost contribution arrangements – a key clarification on deductibility of intra-group costs
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse a recent ruling of the Italian Supreme Court that clarifies the conditions for the deductibility of costs related to intercompany services
Norton Rose Fulbright hires new TP head from Baker McKenzie
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
The UAE R&D tax credit: ten TP takeaways for multinationals
Mithilesh Reddy of Steadfast Business Consulting outlines the key transfer pricing compliance risks, pillar two impacts, and structuring priorities for multinational enterprises under the UAE’s new R&D tax credit regime