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WLA TAX PRACTICE GROUP · PRACTICE 03 OF 6 · SPECIALIST GROUP

CROSS-BORDER TAX.
PILLAR TWO.
TRANSFER PRICING.
ONE CO-PRACTICE TEAM.

WLA Tax co-practice coordinates Pillar Two compliance, transfer pricing, cross-border tax structuring, and M&A tax due diligence — across every jurisdiction of your business simultaneously, under one Institutional framework.

80+
Tax jurisdictions
Pillar Two
EU now operational
OECD BEPS
Framework active
Live
Tax intelligence
WLA TAX INTELLIGENCE · LIVE

TAX SIGNALS THAT
MOVE BEFORE
YOUR MATTER DOES.

WLA Tax Intelligence tracks Pillar Two, transfer pricing, OECD BEPS, and jurisdiction-specific tax developments across every active WLA corridor — updated in real time by our tax specialists in 90+ jurisdictions.

AREA / CORRIDOR
SIGNAL
STATUS
EU / PILLAR TWO
GLOBAL MINIMUM TAX
Domestic Minimum Top-Up Tax Operational — US Multinationals Reviewing EU Exposure
US multinationals with EU subsidiaries reviewing top-up exposure across all EU member states. WLA Tax specialists in Germany, France, Netherlands, Poland, and 12 further EU jurisdictions briefed simultaneously.
ACTIVE
INDIA
INCOME TAX CODE 2025
India Income Tax Code 2025 — Material Changes Effective April 2026
Material changes to depreciation and corporate tax computation effective April 2026. Every cross-border group with India operations must assess impact now. WLA India tax specialist available for urgent brief.
ACTIVE
BRAZIL
TRANSFER PRICING
Brazil Transfer Pricing — OECD-Aligned Rules Now in Force
OECD-aligned transfer pricing rules in force from January 2024, with full retroactive application. Significant cross-border structuring implications for every US↔Latin America and EU↔Latin America corridor participant.
HIGH
PORTUGAL
IFICI / HNW
Portugal IFICI — 20% Flat Rate for Qualifying Income
20% flat rate for qualifying income. Significant planning opportunity for HNW individuals relocating from non-EU jurisdictions. WLA Lisbon preparing client guide for HNW relocation and tax planning mandates.
ACTIVE
UAE
CORPORATE TAX
UAE 9% Corporate Tax — Year Two Compliance Cycle Begins
First full annual corporate tax compliance cycle in UAE. Significant structuring implications for Gulf corridor participants with UAE holding structures. New free zone rules require separate analysis.
ACTIVE
EU
DAC8
DAC8 — EU Crypto-Asset Reporting Framework Active from January 2026
Automatic exchange of information on crypto-asset transactions across EU. Affects EU firms and non-EU counterparties across every WLA corridor involving European jurisdictions with digital asset exposure.
WATCH
GLOBAL
PILLAR ONE
OECD Pillar One — Amount A Framework Implementation Status
Multilateral convention for Amount A being finalised. Significant impact on how large multinationals allocate profits. WLA monitoring closely across all active corridors — particularly US↔Europe and EU→India.
WATCH
WHAT WLA TAX CO-PRACTICE DELIVERS

CROSS-BORDER TAX
NEEDS SPECIALISTS
ON BOTH SIDES.

WLA co-practice means one coordinated team addressing your cross-border tax needs simultaneously — genuine local depth in every jurisdiction, under one Institutional framework. One brief. All jurisdictions.

CO-PRACTICE 01

PILLAR TWO COMPLIANCE

WLA coordinates domestic minimum top-up tax compliance across all EU member states and relevant non-EU jurisdictions — one programme, all jurisdictions. The WLA co-practice team is already briefed on each jurisdiction's implementing legislation and local application rules.

CO-PRACTICE 02

TRANSFER PRICING

Cross-border transfer pricing documentation, benchmarking, and advance pricing agreements — co-practiced with the right tax specialist in each jurisdiction simultaneously. One coordinated approach across every jurisdiction of your group structure.

CO-PRACTICE 03

M&A TAX DUE DILIGENCE

Tax due diligence across every jurisdiction of a cross-border acquisition — WLA coordinates local tax specialists as one integrated due diligence team. All reporting aligned. All findings cross-referenced across jurisdictions.

CO-PRACTICE 04

CROSS-BORDER TAX STRUCTURING

Holding company structures, IP holding vehicles, and investment structures — co-practiced with tax specialists in every relevant jurisdiction for maximum efficiency. WLA ensures the structure works in every jurisdiction, not just on paper.

CO-PRACTICE 05

OECD BEPS COMPLIANCE

Country-by-country reporting, substance requirements, and anti-avoidance rules — coordinated across every jurisdiction of your group structure simultaneously. WLA tax specialists in every relevant jurisdiction aligned on one compliance programme.

CO-PRACTICE 06

HNW TAX PLANNING

Residence planning, domicile structuring, and cross-border wealth tax planning for HNW individuals and family offices — co-practiced with tax specialists in origin, destination, and holding jurisdictions simultaneously.

PRACTICE GROUP LEAD

PEDRO GLORIA
PONCE DE LEÓN.
WLA TAX LEAD.

Every WLA practice group is led by a named WLA partner firm practitioner — personally accountable for the quality and co-ordination of the practice across all jurisdictions.

PG
WLA TAX PRACTICE GROUP LEAD · MEXICO
PEDRO GLORIA
PONCE DE LEÓN
Partner · Gloria-Ponce de León & Hernández (GP&H)
MONTERREY · MEXICO CITY

Pedro Gloria is a partner at Gloria-Ponce de León & Hernández (GP&H), a Mexican law firm with offices in Monterrey and Mexico City. With over 20 years of experience in corporate and tax law, Pedro leads WLA's global Tax Practice Group — co-ordinating Pillar Two, transfer pricing, and cross-border structuring across WLA's 80+ tax jurisdictions.

TAX CORPORATE M&A PILLAR TWO
WLA TAX PARTNER FIRMS · SELECTED
Gloria-Ponce de León & Hernández
Monterrey & Mexico City, Mexico · Tax Group Lead
PRACTICE LEAD
Ulloa & Associates
San Pedro Sula, Honduras · Tax · Immigration · Transactional
WLA PARTNER
SGA Law Africa
Pretoria, South Africa · Tax · Transactional · IP
WLA PARTNER
Law & More B.V.
Eindhoven, Netherlands · Tax · Transactional · Dispute
WLA PARTNER
Mifsud & Mifsud Advocates
Valletta, Malta · Tax · IP · Immigration
WLA PARTNER
35+ Further Jurisdictions
Still open for WLA Tax designation
APPLY →
KEY TAX JURISDICTIONS

WHERE WLA HOLDS
TAX SPECIALISTS.
90+ jurisdictions.

One exclusive WLA tax partner firm per jurisdiction. All connected through the WLA co-practice framework — one brief activates every jurisdiction you need simultaneously.

India
Transfer pricing · Income Tax Code 2025
Germany
Pillar Two · CIT · Trade tax
UAE
Corporate tax · Free zone regimes
Netherlands
Dutch tax treaties · Holding structures
United Kingdom
UK CIT · Diverted profits · DST
France
IS · CVAE · International structures
Singapore
Regional holding · DTAs · ECI
Malta
Participation exemption · IFICI
Mexico
CIT · Transfer pricing · BEPS
Honduras
Corporate tax · Cross-border
South Africa
CIT · Transfer pricing · WHT
Portugal
IFICI · NHR successor · HNW
CROSS-BORDER TAX
NEEDS SPECIALISTS
ON BOTH SIDES.