With the recent wave of personnel cuts at the IRS, a seemingly logical assumption has taken hold: fewer people must mean fewer audits. In practice, the opposite is unfolding. The US tax authority is navigating one of the most disruptive periods in
El pasado 28 de mayo de 2026, Panamá promulgó la Ley 526, una reforma que incrementa significativamente los requisitos de sustancia económica aplicables a determinados contribuyentes. La medida busca reforzar la alineación entre las estructuras corporativas y la actividad económica real desarrollada
The Brazilian tax reform, currently in the process of being regulated after the approval of Constitutional Amendment No. 132/2023, promotes structural changes in the consumption tax system, with the replacement of taxes such as PIS, Cofins, ICMS, and ISS with new modelsbased on the IBS (Tax on Goods and Services) and the CBS (Contribution on Goods and Services). Although these changes are concentrated in indirect taxation, many companies have questioned whether there will be impacts or interactions with the Transfer Pricing rules recentlyadopted in Brazil. In general, Transfer Pricing rules — reformulated by Law No. 14,596/2023 and aligned with the OECD’s arm’s length principle — continue to focus on the correct allocation of results between related parties in different jurisdictions, with direct effects on the calculation of IRPJ and CSLL. The tax reform, on the other hand, has as its main objective the reorganization of taxation on consumption. Thus, under a strictly normative analysis, the two topics remain in different fields of tax legislation. However, from an economic and operational perspective, some interactions may arise. The adoption of a dual VAT system (IBS and CBS) tends to increase transparency and tax neutrality in value chains. This can influence the structuring of operations between companies in thesame group, especially in distribution models, service provision and centralization of functions in certain entities. Changes in the form of consumption taxation may lead multinational groups to review operational flows, which can indirectly impact transfer pricing policies. In addition, companies that carry out intra-group imports and exports may need to assess whether any changes in tax costs or price formation in the domestic market alter the economic assumptions used in their comparability studies. While transfer pricing methods remainfocused on analyzing margins and market conditions between independent parties, structural changes in the economy may require updates to benchmarking analyses and domestic policies. Given this scenario, it is recommended that multinational companies follow the discussions on tax reform and transfer pricing in an integrated manner.
1. Introducción En el contexto de la creciente integración económica global, la valorización de negocios y activos ha adquirido una relevancia central en el ámbito tributario, incluyendo en materia de precios de transferencia. Lo que históricamente se consideraba un ejercicio rutinario de
The scope and complexity of transfer pricing litigation across the Americas have expanded considerably in recent years, reflecting both the increased sophistication of multinational enterprise (MNE) structures and the strengthening of tax authorities’ enforcement efforts. A review of available case law and publicly reported decisions indicates a
Background The case centers on a dispute between the Italian Revenue Agency and Arvin Replacement Products S.R.L. (Taxpayer) regarding the treatment of a zero-balance cash pooling arrangement with its Irish parent company. Under this agreement, the Italian subsidiary’s daily bank balances were automatically transferred
El Servicio de Administración Tributaria (SAT) publicó su quinta edición de parámetros de tasas efectivas de ISR aplicables a grandes contribuyentes, correspondientes a los ejercicios fiscales 2022 y 2023. Esta iniciativa se enmarca en el artículo 33 del Código Fiscal de la Federación, cuyo objetivo es facilitar
The landscape of Australian international tax has undergone a transformation as we move into 2026, with the draft Practical Compliance Guideline PCG 2025/D2 currently remaining in draft status, though expected to be finalized imminently. This marks the end of an era where transfer pricing focused primarily
The entry into force of Law No. 14,596/2023 marked a structural change in the Transfer Pricing regime in Brazil, by aligning national legislation with the arm’s length principle adopted by the OECD. After approximately one year of adapting to the new model,
Global Services Case Background Valuation for transfer pricing and taxation purposes has shifted from a routine compliance exercise into potential future high-stakes litigation. Global tax authorities have increasingly identified technical pitfalls in how multinational enterprises (MNEs) value intercompany transactions. In practice, a variety of
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