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  • Transfer pricing in 2019

    Deloitte Touche Tohmatsu’s global transfer pricing practice, in partnership with International Tax Review, is pleased to present the 2019 edition of the Transfer Pricing Controversy Guide, a discussion and overview of the leading issues, challenges and opportunities around transfer pricing (TP) controversy.

  • Transfer pricing controversy, strategy and future direction

    Transfer pricing controversy has become more frequent and complex following the OECD’s BEPS initiative. Deloitte’s Shaun Austin, Darcy Alamuddin and Jamie Bedford explore how companies can strategically respond and reduce its associated risks.

  • What the tax authorities are up to: Key audit trends globally

    Public and political pressure has seen tax authorities play closer attention to transfer pricing. Deloitte’s Tony Anderson, Alex Evans, Mariusz Kazuch, Rafal Sadowski and Lian Tang He explore changes in Canada, China and Poland.

  • Joint audits, ICAP, and the role of risk assessment

    Cross-border cooperation in transfer pricing risk assessments and audits has presented cost saving opportunities, but increased reporting obligations for MNEs. Deloitte’s Manfred Naumann and David Varley explore the experience in Germany and the US.

  • APAs: A leading practice to resolve and avoid TP disputes

    Multinationals are increasingly resorting to advance pricing agreements (APAs) to manage tax disputes globally. With costs and processing times falling, Deloitte’s Kerwin Chung, Aldo Castoldi, and Luke Tanner discuss their implications in the US, Japan and Europe.

  • From best endeavours to binding arbitration: Eliminating double taxation

    Mutual agreement procedures (MAPs) are becoming increasingly popular in the settlement of TP controversy. As double taxation fears abound for multinationals, Deloitte’s Edward Morris discusses the importance of a well-functioning MAP process.

  • Chicken or the egg: TP, BEPS, and local-country legislation

    Are transfer pricing controversy cases on the rise because of the OECD’s BEPS initiative or local country legislation? Deloitte’s Stan Hales and John Henshall explore the dynamic globally.

  • A national perspective: TP controversy in France, India, and the US

    Transfer pricing (TP) controversies have arisen in all countries. Deloitte’s Eric Lesprit, Sanjay Kumar and Joseph Tobin focus on recent TP controversy developments in three: France, India, and the US.

  • An industry perspective: Financial services, life sciences and automotives

    Post-BEPS, TP controversy has affected all industries. Deloitte’s Ralf Heussner, Aydin Hayri and Juan Ignacio de Molina explore the impact on the financial services, life sciences and automotive industries.


  • The age of the multinational

    Dan Barabas introduces the 2019 International Tax Review Transfer Pricing Controversy guide, in association with Deloitte.

International Correspondents